Government and Foundation Grants
Post-Award Grants Manual
This electronic Grants Manual has been prepared as a resource for faculty 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.
New - 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
Expense Transfer Requests
Budget changes in a grant
No-cost Extension of a grant
Business Office Contact Information:
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 $3,000. 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 (COFAR)
- 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 cost rate
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.
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.
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 Grant Manager 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 Susan Benson, Grant Manager, 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 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.
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
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.
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 Business Office should be contacted before entering into a sub-award arrangement. 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.
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 Back to top
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 Federal award Principal Investigator is responsible for purchasing equipment in accordance with Federal regulations and College purchasing policy. For equipment purchases over $3,000 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 and 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 documents sole source provider. All purchases of this sixe should be reviewed by the Purchasing Manager.
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 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 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 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 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, 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 and request budget adjustments as needed. Budget adjustment requests should be sent to the Business Office. 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 Comptroller and submitted for electronic reimbursement.