Overview of Project Management
Effective sponsored project management supports the PI in accomplishing the statement of work on time, within budget, and in compliance with University policy and sponsor regulations.
What Qualifies as a Direct Cost?
According to Stanford policy and federal regulations, an expense qualifies as a direct cost for a sponsored project when it meets all four of the following criteria.
- Allowable: as defined in OMB Circular A-21, the Uniform Guidance AND in the terms & conditions of specific awards.
- Allocable: Only those expenses that benefit a project may be charged to that project.
- Reasonable: Costs must reflect what a prudent person would pay.
- Consistent: Costs must be handled consistently across the University by following Stanford policy.
Everyone who authorizes expenses at Stanford for any purpose must confirm prior to approving a transaction that the expenditures are:
- Reasonable and necessary
- Consistent with established Stanford policy and practices, as well as sponsor or donor terms & conditions
- Applicable to the work of the Stanford, which includes; instruction, research, and public service
Costs are defined as allowable or unallowable for reimbursement by the government. The federal government asserts that federal funds may not be used to pay unallowable expenses. Unallowable expenses may NOT be charged either directly or indirectly to the federal government.
All expenditures at Stanford, regardless of funding source, must be coded as allowable or unallowable so that they can be appropriately included or excluded from indirect cost calculations.
Are considered appropriate and reasonable by Stanford AND they are eligible for cost reimbursement by the federal government as stated in OMB Circular A-21 or the Uniform Guidance.
Are considered appropriate and reasonable business expenses by Stanford, BUT they are not eligible for reimbursement by the federal government. Departments may incur these expenses but they must code them as unallowable. Use the Oracle Expenditure Codes and Descriptions to find the appropriate code for an expense.
We must understand the distinction between allowable and unallowable costs. It is crucial to code and categorize expenses correctly to comply with Stanford’s obligation to the federal government for both direct F&A or indirect cost recovery. Our ability to obtain federal grants and contracts is dependent upon meeting federal requirements.
The integrity of the Stanford's financial systems depends on the knowledge and skill of each of the individuals who process the thousands of financial transactions every day.
|Expenses that must be coded unallowable for federal reimbursement include:||University activities that federal regulations require to be coded as unallowable for federal reimbursement:|
In addition Stanford does not allow reimbursement for the following. These expenses will not be paid for by Stanford. If incurred, they must be paid for by the individual:
- Personal amusement, social activities, or entertainment (outside of activities directly related to University functions or purposes, including employee-employer relations, performance improvement, etc.)
- Stanford Faculty Club dues for individual members
- Personal, social, or travel club dues
- Stanford parking permits for employees or students
- Traffic citations for either personal or Stanford vehicles
- Personal services or personal purchases
- Interest charges incurred by individuals for late payment of their own personal bills
- Or any costs specifically disallowed by school or department policy
Example of a cost unallowable for reimbursement by Stanford:
A Senior Research Associate purchases a leather brief case and would like to use university funds to pay for the item. The designer briefcase is made of fine grain leather with brass trim and costs $1250.
Explanation: The cost is not reasonable, it is not necessary for the performance of the person's job, and is not permitted by University policy because it is a personal item. It must be paid for by the individual.
Example of a cost unallowable for reimbursement by the federal government, but allowable for reimbursement by Stanford:
An important faculty member is retiring from 35 years of service to Stanford. A party is given in his honor.
Explanation: Although this is something the federal government should not pay for as a direct or indirect cost, it certainly is an appropriate Institutional expense. This event should use the expenditure types: 52310 ALCOHOL BEV UNALW for all alcohol, and 52240 EMP MORALE for the food cost. The expenditure types designated unallowable for reimbursement by the Federal Government in both cases.
Example of a cost unallowable for reimbursement by the sponsor, but allowable for reimbursement by Stanford:
The State of California grant explicitly states no travel outside of the state of California. Professor Smart would like to travel outside the state to present a paper about her research.
Explanation: No matter how great a speaker she is or how interesting her research may be, the expense is unallowable as a direct charge to the sponsor per the award terms and conditions. If Professor Smart does travel, the expense must be charged to a PTA where the travel is Allowable, Allocable and Reasonable. The expenditure type would be: 52410 Domestic Travel Allow.
Terms and Conditions of a Sponsored Project Can Be More Restrictive
UNALLOWABLE costs may also be identified in the specific terms and conditions of a sponsored project. These can be more specific than those outlined in A-21 or the Uniform Guidance.
Example: A sponsor specifies that international travel costs cannot be charged to a particular project. Those costs may NOT be charged to that project, even though Stanford and federal regulation may allow them.
Monitoring Project Expenses within Funding Limitations
It's important for the Research Administrator to monitor the rate of expenditure on a sponsored project because PIs are responsible for the ongoing fiscal management of awarded projects, including regular monitoring against project period budgets. Federal regulations establish the approved project budget as the financial expression of the project, and sponsors may evaluate the project against the budget at any time.
Although sponsors allow certain flexibility's with respect to re-budgeting, un-obligated balances, and pre-award costs, Stanford University and sponsors expect expenditures to be reasonably consistent with the approved project and budget.
Sponsors may question or restrict expenditures that appear inconsistent with the project plan and budget. PIs are obligated to request prior approval when budget and program plan revisions indicate a significant change in scope.
Indicators of a change in scope can include, for example, significant expenditures beyond the amount authorized on the award, or requests for additional funding. PIs are obligated to request prior approval when budget and program plan revisions indicate a significant change in scope. Consult with OSR or your school based management team for additional guidance and for endorsement of the formal request to the sponsor.
For federal grants, advance written approval by the sponsor is required for:
- Change in the scope or the objective of the project or program
- Change in the PI
- Absence for more than three months or a 25% reduction in time devoted to the project, by the approved PI
- Additional federal funding
The transfer, by contract or other means, of a significant part of the
research or substantive programmatic effort (i.e. subaward).
In all cases prior approval must be in writing from the authorized grant or contract officer.
The Uniform Guidance recognizes that a PI can be absent from campus but fully engaged in his or her research team by means of skype, video, computer or other means of communication.
PIs are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section.
(1) Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval).
(2) Change in a key person specified in the application or the Federal award.
(3) 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.
Note that number 3 above does not use the term "absence" but "disengagement" from the project. The distinction is a PI/PD can be off campus and still engaged in the research, which would not require prior written approval.
The new term of disengagement in the Uniform Guidance will become part of Stanford Policy prospectively and retrospectively.
Specific to the School of Medicine, evidence of engagement or disengagement from a sponsored project should be documented on Attachment A of the Sabbatical Leave form which must be reviewed and approved by the School Dean's office, and forwarded to the Institutional Official who will review, counter sign and uploaded it into the appropriate SeRA record(s).
The PI is working in New Zealand on coral reef research as part of the statement of work. She is absent from the Stanford Campus but still engaged in the research.
During the life of a sponsored project, it may become necessary to modify certain aspects of the original award. Such changes may involve rebudgeting of funds among expense classes or adjusting the length of a project period. Many federal agencies have transferred the authority to approve such changes to awardee institutions. Review the terms and conditions of your award.
Approvals Delegated to Stanford
Federal granting agencies have delegated to Stanford the ability to initiate:
To create a sponsored research account for the purpose of incurring pre-award costs up to a maximum of 90 calendar days prior to award start date. Note, however, that any expenditures that precede the award are solely at the financial risk of the unit requesting these expenditures (i.e., PI). Use the PDRF to initiate an early PTA.
No Cost Extensions
To initiate a one-time extension of the award expiration date of up to 12 months (funding agency must be notified of extension at least ten days prior to original termination date). This extension may not be exercised merely for the purpose of using any unobligated balance.
Internal prior approvals are made through your Institutional Representative (OSR or RMG). All requests for a no-cost extension must be approved in advance of the original date of project termination, to allow adequate time for agency notification.
A cost transfer is an after-the-fact reallocation of a transaction cost from one PTA to another. You should charge a cost to the benefiting sponsored project PTA when it is first incurred. However, it may be necessary to transfer a cost to a sponsored project after you initially record that cost. Stanford allows cost transfers involving sponsored projects only in these circumstances.
- to correct an error
- to transfer between tasks of the same sponsored project
- to remove disallowed costs
- to clear an overdraft at the end of a project
A cost transfer invites the assumption that the transaction was not handled properly initially. The charge will be scrutinized for allowability and allocability to the benefiting sponsored project. And the documentation or justification for moving charges will be scrutinized as well
Cost transfers that represent corrections of errors should be completed within 3 months of when the error is discovered, and no later than 6 months after the expense is posted to an award. The 6-month deadline allows 1 month to correct any errors discovered by PIs during the certification process.
Errors found during the required monthly expenditure statement review process should be corrected upon discovery.
All cost transfers must be supported by documentation that fully explains the error as detailed below. An explanation merely stating that the transfer was made "to correct an error" or "to transfer to correct project" is not sufficient.
Cost transfer documentation must include a justification that clearly shows:
- The expense directly benefits the receiving PTA
- The expense is allowable on the receiving PTA
- The reason the expense was charged incorrectly to the first PTA
- That any systematic reasons which might cause this problem to be repeated have been addressed
- The reason for any delay in the timely processing of the transfer
Documentation for large transfers, and transfers within the first or last 90 days of a sponsored project, receive additional central review. Use the Cost Transfer Check List to help you write the documentation and to facilitate a timely review by OSR.
Limitation of Funds
The Limitation of Funds clause is typically inserted in to Federal contracts that are incrementally-funded cost-reimbursement contracts. The clause requires us to notify the sponsor that we are coming to the end of obligated funding, and send notification to the contract officer that obligated funds will be spent within the next 60 days. OSR will initiate the notice to the sponsor. You may also notify OSR when you will require additional incremental funding within the next 60 days. Refer to FAR 52.232-22 for additional information.
Limitation of Costs
The Limitation of Costs clause is inserted into federal contracts when they have been fully funded. The clause requires us to notify the sponsor when we expect in the next 60 days to have spent 75% of the estimated cost, or expect expenses to be greater or substantially less than previously estimated. Refer to FAR 52.232-20 for additional information.
No Cost Extension (NCX)
As a project comes to the end of the period of performance, additional time may be required to complete the project. You can request a no cost extension (NCX). In doing so, you affirm that additional work remains to be completed on the project and that resources are available to continue to support the project, or that additional time is needed to provide for an orderly closeout. The fact that funds remain at the expiration of the grant is not, in itself, sufficient justification for an extension without additional funds.
Many federal agencies allow for Stanford to approve a one-time no cost extension for a period of up to 12 months beyond the original expiration date shown in the NoA if all the following criteria are met.
No term of the award specifically prohibits the extension,
No additional funds are required to be obligated by the NIH awarding IC, and
The project's originally approved scope will not change
Contracts typically require a formal request to the sponsors contracting officer and a subsequent modification to the contract.
Review the terms and conditions for more guidance.
To request a NCX consult the Sponsored PTA Manager - Dept User Guide