Government and Foundation Grants
Post-Award Grants Manual
This electronic Grants Manual has been prepared as a resource for Principle Investigators (PIs) and Project Directors who have received grants from federal or other external sources. 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.
Office of Management and Budget Uniform Guidance
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 Grants
Cost Principles & Allowable Expenses
Cost Transfers and Audit Red Flags
Budget changes in a grant
No-cost Extension of a grant
Office of Management and Budget Uniform Guidance
On December 26, 2013, the Office of Management and Budget (OMB) issued Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards in the Federal Register to improve the effectiveness and efficiency of Federal financial assistance. The “Uniform Guidance" replaces the administrative, accounting, audit rules and principles publicized in the OMB Circulars, including A-21, A-110, and A-133.
Administrative requirements and cost principles apply to new awards and to additional funding (funding increments) to existing awards made after December 26, 2014. Existing federal awards will continue to be governed by the terms and conditions of the federal award.
Objectives of the OMB Uniform Guidance (UG)
- Eliminate duplication and conflicting guidance
- Focus on performance over compliance for accountability
- Encourage efficient use of information technology and shared services
- Provide for consistent and transparent treatment of costs
- Limit allowable costs to make the best use of federal resources
- Set standard business processes using data definitions
- Encourage non-federal entities to have family-friendly policies
- Strengthen oversight
- Target audit requirements on risk of waste, fraud, and abuse
Competition in grants; increases competition for federal grant funds
- Public notice for grants (200.202) — Federal awarding agencies must notify the public of federal programs through the Catalog of Federal Domestic Assistance (CFDA).
- Merit-based review of proposals (200.204) — Federal awarding agencies must design and execute a merit review process for all grant applications.
- Risk analysis of potential grantees (200.205) — Prior to making a federal award, an agency must have a framework in place to determine the eligibility and risks of applicants.
- Standardization of information (200.206) — In an attempt to reduce the huge variation between federal agencies, the Omni Circular requires each federal award to include 15 uniform data sets, including the timing and scope, and expected performance and outcomes.
Administrative requirements; includes significant reforms to current administrative requirements (formerly circulars A-102, A-110, and A-89).
- Mandatory disclosure (200.113) — Organizations must disclose all violations of federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the federal award. Failure to make the required disclosures can result in suspension and/or debarment from government grants.
- Conflict of interest (200.113) — Non-federal entities must maintain conflict of interest policies as well as written policies on organizational conflict of interest to protect the integrity of procurements under federal awards and sub-awards.
- Greater responsibilities for sub-recipient monitoring (200.331) — Pass-through entities must include (at the time of a sub-award) an approved, federally recognized indirect cost rate negotiated between the sub-recipient and the federal government. If no such rate exists, either a negotiated rate or a 10 percent de minimis rate, should be included.
- Greater focus on internal controls (200.303) — Organizations must establish and maintain effective internal controls over federal awards to provide reasonable assurance that awards are being managed in compliance with laws and regulations. Non-federal entities must also take measures to safeguard personally identifiable information.
- Definition of supplies (200.94) — If the acquisition cost of computer equipment is less than the capitalization level established by the non-federal entity for financial statement purposes, or $5,000 (regardless of the length of the device's useful life), it should be considered a supply. In addition, the final guidance includes a new micro-purchase procurement method. This method applies to the purchase of supplies or services when the aggregate dollar amount does not exceed $3,500. If the non-federal entity considers the price reasonable, these purchases may be awarded without soliciting competitive quotes.
- Performance measurement (200.301) — Recipients of federal awards must relate financial data to the performance accomplishments of an award. Recipients must also provide cost information to demonstrate cost-effective practices.
- Cost sharing (200.306) — Voluntary committed cost sharing cannot be used as a factor during the merit review of applications or proposals, but may be considered if it is both in accordance with federal awarding agency regulations and specified in a notice of funding opportunity. For research projects, only mandatory cost sharing or cost sharing specifically submitted in the project budget will be included for computing indirect costs. Voluntary committed cost sharing is not expected under federal research proposals.
Cost principles; significant reforms to cost principles (formerly circulars A-21, A-87, and A-122).
- Indirect costs (200.414) — Federal agencies and pass-through entities must accept a negotiated indirect cost rate if one exists, or negotiate a rate in accordance with federal guidelines. There are exceptions when a statute or regulation requires it, or if the head of the agency approves it based on publicly documented justification.
- Non-federal entities that have never had a negotiated indirect cost rate may use a rate of 10 percent of modified total direct costs.
- Entities with an approved federally negotiated indirect cost rate can now apply for a one-time extension of up to four years without further negotiation.
- Administrative salary direct costs (200.413) — In certain circumstances, administrative costs can be charged directly when there is prior approval and the costs are specifically allocated to one award. Administrative and clerical staff salaries are normally treated as indirect costs, but direct charging may be appropriate if:
- The services are integral to a project or activity
- Individuals involved can be specifically identified with the project or activity
- Costs are explicitly included in the budget or have prior written approval of the awarding agency
- The costs are not also recovered as indirect costs
- Compensation (200.430)— To prevent duplicating efforts in entities that have good internal controls, the final guidance allows for alternatives to the current reporting requirements for salaries and wages. Auditors must test these internal controls. Federal agencies can also now approve alternative accounting methods for salaries and wages based on the achievement of performance outcomes. This includes areas that blend funding from multiple programs.
- Materials and supplies (200.453) — Materials and supplies used for the performance of a federal award are typically charged as direct costs. Going forward, computer equipment can be charged as direct costs if they are essential and allocable, but not solely dedicated, to the performance of a federal award.
- Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
- Frequently Asked Questions, Council on Financial Assistance Reform
- Uniform Guidance Crosswalk from Existing Guidance to Final Guidance
- NSF - Significant Changes and Clarifications to the Proposal and Award Policies and Procedures Guide
Pre-Award: Grant Proposals Guidelines
Proposals for grants of all types should originate in the Office of Corporate and Foundation Relations. 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 costs charged to federally funded 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 (IDC) is negotiated by the Business Office with the Department of Health and Human Services following a prescribed formula. Rate as of July 1, 2015: Our IDC rate based on our Audited Financial Statements for the period ending June 30, 2014 has been approved at a rate of 57.0% for federal grants awarded on July 1, 2015 through June 30, 2017, and 58.0% for federal grants awarded on July 1, 2017 through June 30, 2019. The IDC on current grants is not altered by this new rate. The IDC rate in effect at the time of the initial awarding of a grant is in effect throughout the life of the grant. The negotiated rates must be accepted by all Federal awarding agencies (§200.414). Exceptions are allowed only when required by Federal statute or regulation or when approved by a Federal awarding agency head or delegate based on publicly documented justification.
Pass-through entities must honor an organization’s negotiated indirect cost rate, or if no such rate exists, either a rate negotiated between the pass-through entity and the sub-recipient, or a deminimis indirect cost rate may be used. 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 7.65% for faculty summer stipends. The 35% rate may be subject to change as the cost of providing benefits changes. For student stipends, the benefit rate should be budgeted at 7.65%. We use the same benefit rate for all grants regardless of type or size so that all are treated equally under the budget guidelines. These percentages are intended to provide adequate funding to cover the actual fringe benefit costs that will be charged to the sponsors.
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.
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 Grant Manager in the Business Office. Post-award orientation provides an opportunity to discuss the grant award, reporting requirements, policies and procedures, and to familiarize the new Principle Investigator (PI) with the resources available. If other personnel will assist with the grant, they should attend the orientation as well.
Once the College has received the official award notification, Corporate and Foundation Relations notifies the Business Office and Central Records 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 whomever they authorize, will have online access to their grant activity on the Hub. The following documents must be received before the account number will 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 the 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
- Certify Time and Effort as it applies to the grant
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 with federal grants must be familiar with allowable costs (see Allowable Expenditures for additional detail). For federally funded grants, the Business Office will, on a quarterly basis, 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. Electronic certification is also permitted. 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 September, December, March and June. The certification statement is due by the 15th of the following month (November 15, February 15, May 15 and August 15).
Salary and wages for Faculty, Staff, and Students: New employees
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 funded by the National Science Foundation 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 grant budget. After-the-fact Time and Effort Certification (required for federal grants only) is obtained in the fall (see Effort Certification 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.
Summer Student Research and Employment Information
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 event has been completed. Full-time exempt employees under contract with Carleton College are not eligible to receive additional compensation from government grants. Part-time exempt staff are only eligible for stipends if the work/workshop occurs outside of their regular work calendar. For faculty with a split appointment between faculty/staff, please contact Human Resources for guidance. PIs who draw 2/9 summer salary from an NSF grant are prohibited from receiving additional compensation from other NSF Grants per NSF guidelines. Back to top
Effort Certification Reporting Requirements
As a recipient of federal funds Carleton College must comply with the Office of Management and Budget (OMB) §200.430 Cost Principals of the Uniform Guidance (UG), which went into effect December 26, 2014, and requires that any compensation for personal services be based on the institution’s records and those records must accurately reflect the work performed.
While UG has shifted focus towards internal controls rather than specific documentation, Carleton College will continue to utilize the after-the-fact effort reporting system currently in place at the recommendation of our Auditors. This process ensures that salary and wages are properly expended and that actual effort is consistent with the originally budgeted effort.
The distribution of salaries for employees working on federally funded projects will be supported by Time and Effort Certification Report form. Hourly employees and student workers will not use this form as their time is certified via electronic time sheets. Recipients of workshop stipends or other onetime payments are certified with the stipend request form.
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.
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.
Under the Uniform Guidance (200.456), federal sponsors may allow PIs to budget and charge for participant support costs. Participant Support Costs include: stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participant or trainees (but not employees) in connection with conferences or training projects.
Participant support costs are not routinely allowed on research projects, but can be charged if the project incudes an education or outreach component and the federal agency approve such costs. Human subject payments are not considered participant support costs.
Participant Support Costs are listed in a separate category on the grant budget and object code 5820 has been created for these expenses (i.e. 28-xxxx-xxxx-5820). Funds budgeted for participant support costs may not be reallocated to other budget lines without prior approval from the funding agency.
If a subaward is issued where participant support has been budgeted, the PI must monitor subaward invoices to ensure that the Participant Support Costs are being account for separately, and that the costs are allowable and allocable.
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.
Suspension – A disqualification from government contracting and subcontracting for a temporary period of time because a company or individual is suspected of engaging in criminal, fraudulent, or seriously improper conduct. Suspension is to be used on an interim basis pending debarment proceedings.
Debarment – An exclusion from government contracting and subcontracting for a reasonable, specified period of time because an individual or vendor failed to perform or their performance was inadequate.
The College will assure compliance with this federal regulation with confirmation from the System for Award Management (SAM) (https://www.sam.gov/portal/public/SAM/). 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. Accounts Payable stamps the invoice indicating debarred/not debarred status of the vendor for audit verification.
Uniform Guidance: General Procurement Standards effective 7/1/17 (200.318)
While many of the key requirements are outlined below, it is important to fully read the procurement sections of the Uniform Guidance, located at 2 CFR 200.318, to ensure compliance.
Some of the general standards over procurement include:
- Every non-federal entity receiving federal awards must have documented procurement procedures that reflect federal law, Uniform Guidance standards, and any state regulations.
- Entities should focus on the most economical solution during the procurement process, and must avoid using federal funds for the acquisition of unnecessary items. Organizations are encouraged to consider the use of shared services and intergovernmental agreements to foster greater economy and efficiency.
- Written conflict-of-interest policies are required. No employee or agent of the entity may participate in the selection, award, or administration of a contract funded by federal grant dollars if he or she has an actual or apparent conflict of interest.
- The organization must document the procurement steps and activities required to be completed. This includes the basis for the type of procurement, contract type, and the basis for the contractor selection and price.
- Ultimately, the recipient of federal awards must maintain an appropriate level of oversight to ensure that contractors perform in accordance with the terms of their contract.
The Uniform Guidance outlines five methods of procurement:
- Micro-purchase (200.67): The purchase of supplies or services where the aggregate dollar amount does not exceed $3,500 as of October 1, 2015 (per FAR). When practical, micro-purchases should be distributed among qualified suppliers and may be awarded without solicitations if the price is considered to be reasonable.
- Use own judgment in identifying potential suppliers.
- When possible, use Carleton discounts
- Installment payments less than $3,500 towards a larger purchase are not considered micro-purchases
- Small purchase: The acquisition of supplies, services or equipment in the range of $3,501 to $150,000. Price or rate quotations, when used, must be obtained from an adequate number or qualified sources prior to making a purchase.
- Documentation for at least three price quotes to support the vendor selection must be submitted to the Randie Johnson, Purchasing and Risk Manager, prior to making the purchase.
- Documentation must be in writing from the vendors and may include screen shots from websites, copies of published price lists and advertised pricing in established magazines or journals.
- If assistance is needed to obtain three quotes, please contact Randie Johnson, Purchasing and Risk Manager.
- Sealed bids: Used for acquisitions costing more than $150,000, bids are publicly solicited and a firm fixed price contract is awarded to the responsible bidder whose bid is the lowest price.
- Competitive proposals: Used for purchases costing more than $150,000, conducted with more than one source submitting an offer, and either a fixed price or cost-reimbursement contracts is awarded. The contract should be awarded to the firm whose proposal is most advantageous to the project, with price being one of the factors considered.
- Please contact Randie Johnson, Purchasing and Risk Manager, for assistance with the competitive bid process.
- Noncompetitive proposals: May be appropriate only when certain criteria are met. For example, when an item is only available from one source, when a public emergency does not allow time for the competitive proposal process, when the federal awarding agency authorized, or after several attempts at the competitive process, the competition is deemed inadequate. (vendor selection form provides checklist)
The following rules apply to all purchases:
- The purchase must comply with Carleton’s documented procurement procedures
- The purchase must be necessary to carry out the Federal award
- The purchase must be made with open competition to the extent required
- The purchase is in compliance with Carleton’s conflict of interest policy
- The purchase documentation contains sufficient and proper history of the purchase
Cost Principles and Allowable Expenses
Allowable, Reasonable, and Allocable are the basic considerations for whether a cost can be included in a budget for a Federal award. Though these principles may change depending on the project, they must be used to determine whether the costs are appropriate for a sponsored project. The cost principles relating to expenditures on federal awards are contained in the OMB Uniform Guidance (UG), Subpart E, 200.400-409.
Consider the following cost principles when deciding if a cost is allowable:
Cost Principles: Allowability (200.403)
- Is the cost reasonable and necessary for the program?
- Is the expense in compliance with laws, regulations and grant terms?
- To what extent is the expense allocable to the grant?
- Is the cost adequately documented?
- Is it consistent with grantee rules that apply to both Federally funded and non-Federally funded activities?
Cost Principles: Reasonable (200.404)
- A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.
- Consideration: Do sound business practices support the expenditure?
Cost Principles: Allocable Costs (200.405)
- Allocable means the good or service can be assigned to an award or cost objective in accordance with the relative benefit achieved.
- If a cost benefits two or more projects, activities, or programs in proportions that can be determined without undue effort or cost, the cost should be allocated to the projects based on the proportional benefit.
While UG provides thorough guidance, 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
Grant expenditures are processed through Accounts Payable and 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.
Additional Related College Policies:
Signing Authority: Authorization for Purchase Orders
Employee Travel and Reimbursement
Travel and Related Expenses (200.474)
Domestic and foreign travel must follow these guidelines as well as Carleton’s Employee Travel and Reimbursement policy, whichever imposes the greater restrictions, if travel is allowed on the grant.
Lodging and Subsistence:
Costs incurred by employees for travel, including lodging, other subsistence, and incidental expenses must be considered reasonable and otherwise allowable only to the extent that such costs do not exceed charges normally allowed by Carleton in its regular operation as stated on the college’s travel policy.
Federal regulations require travelers to incur the lowest possible expense to the federal award; in most circumstances, this is a non-refundable (restricted) economy class airfare.
Federal regulations require that airfare costs in excess of the lowest economy fare class are unallowable except when such accommodations would:
- Require circuitous routing;
- Require travel during unreasonable hours;
- Excessively prolong travel;
- Result in additional costs that would offset the transportation savings; or
- Offer accommodations not reasonably adequate for the traveler's medical needs.
Once these criteria are met, the traveler must justify and document the exception for the use of business-class or upgraded economy airfare to be allowable on a federal award. Complementary (no-cost) upgrades are allowed.
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). One exception to this requirement is transportation provided under a bilateral or multilateral air transport agreement, to which the U.S. government and the government of a foreign country are parties, and which the Department of Transportation has determined meets the requirements of the Fly America Act.
The U.S. government has entered into several air transport agreements that allow federal funded transportation services for travel and cargo movements to use foreign air carriers under certain circumstances. There are currently four bilateral/multilateral “Open Skies Agreements” (U.S. Government Procured Transportation) in effect. Information on the four Open Skies Air Transportation Agreements (U.S. Government Procured Transportation) and other specific country agreements may be accessed via the Department of State’s website.
The Principal Investigator is responsible for purchasing equipment in accordance with Federal regulations and College purchasing policy.
For equipment purchases over $3,500 to $150,000, the Vendor Selection Form must be completed and three bids provided prior to making the purchase. (This may have been completed during the grant proposal stage.) Documentation needs to be in writing from the vendors and can include screen shots from websites, copies of published price lists, or advertised pricing in established magazines or journals.
There may be situations where there is a sole source provider of the equipment. This must be documented and approved. Convenience, a good deal, or poor timing are not reasons for bypassing the bid process. Computer purchases up to $5,000 are considered supplies and do not require the bid process.
Equipment purchases greater than $150,000 require bids or competitive proposals unless there is a documented sole source provider. All purchases of this size should be reviewed by the Purchasing Manager.
200.33 Equipment means tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-Federal entity for financial statement purposes, or $5,000.
200.439 Equipment Title. Subject to the obligations and conditions set forth in this section, title to equipment acquired under a Federal award will vest upon acquisition in the non-Federal entity.
The College will tag new equipment and perform physical inventories once every year.
See also 200.439 Equipment and other capital expenditures.
Disposal of Equipment
The OMB Uniform Guidance, section 2CFR 200.310-316 and 200.329, address the various types of property that may be acquired with federal funds. The definition of equipment is “a piece of tangible personal property having a useful life of more than one year and a unit acquisition cost exceeding $5000.” If the recipient no longer has a need for the equipment, the recipient shall request disposition instructions from the College Purchasing Manager. For more information regarding the disposal of equipment, please see the Property Disposal policy in the College Handbook.
Cost Sharing (200.306)
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. Cost sharing or matching agreements should be approved during the proposal stage. After the grant is awarded, it is useful to meet with the Grant Manager and those “contributing” to the match to clarify what form the match will take, and the timeline 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 Grant Manager in the Business Office for review. The basic cost allowability test for the cost share or match (non-federal share of expenses) per per OMB Uniform Guidance, part 200.306, 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)
Cost Transfers and Audit Red Flags
A cost transfer is an after-the-fact journal entry that transfers an expense onto a federally funded award that was previously charged to a different account. All costs should be charged to the appropriate federal award when first incurred, however, there may be circumstances when transfers may not be avoided.
Principal Investigators (PIs) have the primary responsibility for ensuring compliance with federal regulations, as well as monitoring expenditures, the proper allocation of expenses, and the timely detection and correction of errors.
To comply with the cost allowability and allocability requirements outlined in the Uniform Guidance (200.400 - Subpart E - Cost Principles) , the college must be able to explain and justify all charges transferred onto federal awards. Any necessary cost transfers should be completed in a timely manner and with a complete explanation per the principles outlined in the Uniform Guidance (200.400 - Subpart E - Cost Principles) , critical factors in supporting allowability and allocability. 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. Simply stating that the transfer is to correcting an error or to move an expense to a correct account is not sufficient
- Cost transfers must be approved by the PI or an authorized member of the project team
- Transfer to grant accounts should be requested within 90 days of the expense (inappropriate expenses to a grant can be removed without a deadline)
- Transfer to a grant made over 90 days from the original posting date must include supporting documentation explaining why the charge is allocable, allowable and reasonable
- 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
Procedure for processing cost transfers:
- Cost transfers are submitted online by the PI or other authorized personnel using the Journal Entry/Transfer request form found on the Business Office website under Business Office Forms
- Provide detail description and attached supporting documentation as needed
- Cost transfers are reviewed and approved by the Grant and Cash Manager and processed by the Staff Accountant. Supporting documentation provided will be uploaded and linked to the journal entry.
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 (200.308)
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 and request budget adjustments as needed. Before requesting to move funds from one budget line to another, check the terms and conditions of the prime award to determine any established limits or restrictions. Prior approval from the sponsoring agency may be required for one or more of the following:
- Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval).
- Change in a key person specified in the application or the Federal award.
- The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
- The inclusion, unless waived by the Federal awarding agency, of costs that require prior approval in accordance with Subpart E—Cost Principles of this part or 45 CFR Part 74 Appendix E, "Principles for Determining Costs Applicable to Research and Development under Awards and Contracts with Hospitals," or 48 CFR Part 31, "Contract Cost Principles and Procedures," as applicable.
- The transfer of funds budgeted for participant support costs as defined in § 200.75 Participant support costs to other categories of expense.
- Unless described in the application and funded in the approved Federal awards, the subawarding, transferring or contracting out of any work under a Federal award. This provision does not apply to the acquisition of supplies, material, equipment or general support services.
- Changes in the amount of approved cost-sharing or matching provided by the non-Federal entity. No other prior approval requirements for specific items may be imposed unless a deviation has been approved by OMB. See also § 200.102 Exceptions and § 200.407 Prior written approval (prior approval).
Budget revisions requiring prior approval must be coordinated with Corporate and Foundation Relations (CFR) and the Business Office. The Principal Investigator will present the rationale and budget details for the proposed change. Upon approval, the submission will be initiated by CFR as per awarding agency protocol.
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. Please contact Corporate and Foundation Relations for assistance when requesting a no cost extension.
Grantee-Approved Extension: Grantees may authorize a one-time extension of the expiration date of the grant of up to 12 months if additional time beyond the established end date is required to assure adequate completion of the original scope of work within the funds already made available. This one-time extension may not be exercised merely for the purpose of using the unliquidated balances. Grantees are not authorized to extend an award that contains a zero balance. The grantee shall notify NSF, providing supporting reasons for the extension and the revised period of performance, at least ten calendar days prior to the end date specified in the grant to ensure accuracy of NSF’s grant data. All grantee-approved extension notifications must be submitted via use of NSF’s electronic systems.1 For grantee-approved extensions, no amendment will be issued. The revised end date can be viewed via NSF’s electronic systems.
NSF-Approved Extension: If additional time beyond the extension provided by the grantee is required and exceptional circumstances warrant, a formal request must be submitted via use of NSF’s electronic systems. The request must be submitted to NSF at least 45 days prior to the end date of the grant. The request must explain the need for the extension and include an estimate of the unobligated funds remaining and a plan for their use. As indicated above, that unobligated funds may remain at the expiration of the grant is not in itself sufficient justification for an extension. The plan must adhere to the previously approved objectives of the project. All requests for NSF-approved extensions must be submitted via use of NSF’s electronic systems.
The first no-cost extension request will be subject to the approval of the cognizant NSF Program Officer. The Sponsored Projects Office and PI will be electronically notified of the disposition of this request by the cognizant NSF Program Officer. The second no-cost extension will be subject to the approval of an NSF Grants and Agreements Officer, and, if approved, will be in the form of an amendment to the grant specifying a new end date. Grantees are cautioned not to make new commitments or incur new expenditures after the end date in anticipation of a no-cost extension.
Two-Year Extensions for Special Creativity: A Program Officer may recommend the extension of funding for certain research grants beyond the initial period for which the grant was awarded for a period of up to two years. The objective of such extensions is to offer the most creative investigators an extended opportunity to attack adventurous, "high-risk" opportunities in the same general research area, but not necessarily covered by the original/current proposal. Awards eligible for such an extension are generally continuing grants. Special Creativity Extensions are normally initiated by the NSF Program Officer based on progress during the first two years of the grant; PIs will be informed of such action a year in advance of the end date of the grant. In response to the Program Officer's recommendation, the PI should submit the required information electronically via the supplemental funding request module in FastLane.
The eRA Commons' No-Cost Extension feature allows the grantee organization to electronically submit a notification that the organization plans to use its one-time authority to extend the final budget period of a project period of a grant. This extension is without extra funding and available for up to 12 months of additional time, provided the Notice of Award does not prohibit the extension and the project's approved scope will not change. Use of eRA Commons to submit No-Cost Extensions is required.
Note that the No-Cost Extension may be requested only by the Signing Official, no earlier than 90 days before the end of the project period and no later than the project's end date. An email is sent to the funding agency's Grants Management staff when a Signing Official submits the extension. The awarding office will revise the project period end date and send a confirmation to the grantee.
The federal government allows grant recipients to draw down funds electronically Research.gov (NSF), Dpm.psc.gov (NIH) and G5.gov (DOE). Carleton College draws down grant funds after costs have been incurred for grant related expenditures. The following is the cash management procedure:
- PIs approve all allowable grant expenditures. Carleton pays for the approved expenditures through established accounts payable and payroll processes.
- Grant expenditures are coded with unique General Ledger account codes that separate them from other college expenditures.
- NSF: No less than quarterly, Budget to actual summary report is prepared to determine current expenses. The payment request is approved by the Comptroller and funds are drawn by the Grant Manger via Research.gov
- NIH: Budget to actual summary report is pulled and used to prepare and submit the quarterly FFR via Dpm.psc.gov.
- DOE: PELL and Direct Loan draws are regularly requested from Student Financial Services to the Grant Manger to draw via G5.gov. At that time, SEOG and CWS are also evaluated to determine if fund draws are necessary.
- Cash drawn down from the various agencies is credited to the College’s corresponding grant accounts receivable accounts.