GRANT POLICIES: “Do’s and Don’ts” Rebecca Bound, Research Administrator, College of Agricultural and Life Sciences, University of Wisconsin-Madison Cheryl.

GRANT POLICIES: “Do’s and Don’ts”

Rebecca Bound, Research Administrator, College of Agricultural and Life Sciences, University of Wisconsin-Madison

Cheryl Deering, Compliance Specialist, College of Agricultural and Life Sciences, University of Wisconsin-Madison

Ron Ravel, Managing Officer, Research and Sponsored Programs, University of Wisconsin-Madison

1. DO refer to the OMB circulars often.

• A-21: Cost Principles for Educational Institutions

• A-110: Uniform Administrative Requirements for Grants & Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations

• A-133: Audits of States, Local Governments, and Non-Profit Organizations

1. DO refer to the OMB circulars often

• We set up our processes and policies in accordance with A-110, so that we’re compliant with A-21, so that we don’t end up in trouble with A-133.

2. DO work well in advance on proposals.

• Review program guidelines carefully and thoroughly• Know what forms and information are required• Check funding mechanism• Avoid technical difficulties, especially with electronic

submissions• Build budgets carefully and painstakingly

3. DO know whether you will need a protocol

Use of Animals in Research, Teaching, and Outreach–Animal Welfare Act 1966 minimum acceptable standard

–Regulatory Oversight:•USDA/Registration Animals = mammals•OLAW/PHS Assurance Animals = vertebrates

–PHS funded agencies within DHHS–Department of Agriculture–NIH–Department of Defense…..

3. DO know whether you will need a protocol

• Biosafety

– When do you need a protocol from the Institutional Biosafety Committee (IBC)?

– For the use of rDNA, this is the joining of any natural or synthetic DNA segments to DNA molecules that can replicate in a living cell

– Institution often requires IBC review for materials and pathogens that pose a risk to humans, animals, and plants. Broader purview is a matter of institutional discretion

– IBC conducts a risk assessment of the PIs research, to ensure the environment and public health is not jeopardized

3. DO know whether you will need a protocol

Human Subjects• Intervention• Private Information

Research• Generalizable Knowledge• Will you publish in a peer reviewed publication?• Informed Consent• Levels of Institutional Review Board (IRB) review Exempt,

Expedited, Full Committee

4. DO know the process for obtaining a protocol on your campus

5. DON’T start work until protocols are in place

• DO:Remind PIs that grant funds can not go to account set-up until required clearances have been satisfied

• DO Ask Questions: Protocol approved?• Does the scope of the project need to be added to the

currently approved protocol? • Will the protocol expire soon?• Grant sponsor, title, and number listed?• Recombinant DNA part of the project?• Human Subjects?

• Don’t be afraid to contact your campus experts!

6. DO respond quickly to requests for information at time of award

• Get off to a good start with the sponsor/grants officer

• Ensure that the award is in place when the PI needs it

• Information still fresh in everyone’s memory

7. DO take necessary steps to ensure that costs are allocated appropriately• Avoid cost transfers• Don’t park expenses• Utilize accounts in advance• Effort commitments

8. DO monitor subrecipients from proposal through award closeout

• Proposal– Collect paperwork early (institutional and individual)– Check for all appropriate signatures– Review budgets

• Award– Agreements in place timely– Monitor progress and use of funds

• Closeout– Consider setting end date prior to award expiration– Collect all sponsor-required paperwork

9. DO follow guidelines for committing, tracking, and reporting cost share and match

Cost sharing or matching means that portion of project or program costs not borne by the Federal Government.– Committed by an entity other than the sponsor

• Mandatory (required by Sponsor for eligible submission)– Sponsor Policy or by Statuette – Program requirements (details in RFP, solicitation)• USDA Specialty Crop Research Initiative

• Voluntary (not required by Sponsor)– Quantifiable commitments in budget justification or

proposal– May be encouraged in RFP

• 3rd party cost share

9. DO follow guidelines for committing, tracking, and reporting cost share and match

Commitments must be:• Verifiable from the recipient's records. • Not included as contributions for any other federally-assisted

project or program.• Necessary and reasonable for proper and efficient

accomplishment of project or program objectives (A-21).• Allowable under the applicable cost principles (A-21).• Not paid by the Federal Government under another award,

except where authorized by Federal statute to be used for cost sharing or matching.

• Provided for in the approved budget when required by the Federal awarding agency.

10. DO communicate and work closely with your Sponsored Programs Office

• They are the authorized signatory office for all proposals, agreements, and awards

• Awards are submitted by and made to the institution

11. DO know what post-award actions require prior approval

• Change in scope or objective of the project• Change in key personnel listed in the application or

award document• The absence for >3 months or 25% reduction in time by

the PI• The need for additional Federal funding• The transfer of amounts budgeted for indirect costs to

account for increases in direct costs (if approval for such is required)

…and which ones may not.

• Pre-award costs 90 calendar days prior to award• One-time extension of the expiration date of the

award of up to 12 months (with written request at least 10 days before the current project expiration)

• Carry forward of unobligated balances to subsequent funding periods

DO familiarize yourself with cost principles

• OMB circular A-21: Allowable, Allocable, Necessary, Permissible, Consistently Treated

• OMB circular A-21 Section J: Allowability of selected items of cost

12. DON’T wait until the last month of the award to prepare for closeout

• Recipients are responsible for managing and monitoring each project, program, subaward, function or activity supported by the award and ensuring subrecipients have met audit requirements.

• Ensure that indirect costs have been allocated correctly• Final Financial and Technical Reports• Financial Status Reports

– Quarterly <= Frequency <= Annually– A final report shall be required at the completion of the agreement.– Due within 90 days after the end date of the award

• Take necessary action to insure against chargesafter the end date of the award

13. DO keep in mind after final reporting…

• Record Retention• Records to be retained for 3 years from submission of

final expenditure report• For awards that are renewed quarterly or annually, 3

years from the date of the submission of the quarterly or annual financial report

• The recipient shall promptly refund any balances of unobligated cash advanced by the Federal Agency.

• When authorized by the terms and conditions of the award, the Federal awarding agency shall make adjustments to the Federal share of costs after closeout reports are received.

13. DO keep in mind after final reporting…

• The right of the Federal awarding agency to disallow costs and recover funds on the basis of a later audit or other review.

• The obligation of the recipient to return any funds due as a result of later refunds, corrections, or other transactions.

• Audit requirements • Property management requirements

14. DO remember: We are all in this together to make sure that the proposal and research

are a success!

Additional Resources

OMB Circulars• http://www.whitehouse.gov/omb/circulars/

a021/a21_2004.html• http://www.whitehouse.gov/omb/circulars/

a110/a110.html• http://www.whitehouse.gov/omb/circulars/

a133/a133.html