Managing Your Award

Introduction

According to Stanford policy, PIs are responsible for the ongoing fiscal management of awarded projects, which includes regular monitoring against project period budgets. The Research Administrator supports the PI in fiscal management

Monthly Review by the Research Administrator 

Sponsored project and cost sharing accounts must be reviewed by the Research Administrator and the review recorded/verified quarterly in the eCertification system. Review is expected to be completed before the quarterly certification by the PI.

Any questionable charges must be brought promptly to the PI's attention, and, if needed, corrected by an appropriate transfer. Transfers should be initiated as soon as possible after a need has been identified. Procedures governing transfers of expense are defined in RPH, 15.8 Cost Transfer Policy for Sponsored Projects.

The following certification statement appears in the eCertification System. The Research Administrator will acknowledge the following attestation in the eCertification system.

I have reviewed the three months of expenditures for this quarter. To the best of my knowledge, all expenditures are appropriate. Where required, corrections have been or will be made through the accounting system. I understand that to be considered timely all corrections must be made in accordance with RPH 15.8, Cost Transfers for Sponsored Projects.  

Quarterly Review by the Principal Investigator 

The PI has overall responsibility for the technical and fiscal management of a sponsored project. This includes the management of the project within funding limitations, adherence to reporting requirements and assurance that the sponsor will be notified when significant conditions related to project status change. While responsibility for the day-to-day management of project finances may be delegated to administrative or other staff, accountability for compliance with Stanford policy and sponsor requirements ultimately rests with the PI.

The purpose of the review and certification is to confirm that all expenses charged to the account are allowable, allocable to the project, and reasonable. The certification of salary expenditures confirms that salaries charged to the account are supported by a corresponding expenditure of effort during the time period being certified. The certification also assures that other expenditures are for items or services purchased and used during the project period as specified by the award.

The following certification statement appears in the eCertification System.

As the principal investigator I confirm that to the best of my knowledge, salary and wages charged to this project are appropriate in relation to work performed on this project. All other costs charged to this project are, to the best of my knowledge, appropriate. Where required, corrections have been or will be made through the accounting system.

Changes in Approved Project and Budget 

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 and consult your IO (institutional Official).

Federal Grantors require PIs to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions as noted below. 

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 key personnel.
3. The disengagement from the project for more than three months—or a 25 percent reduction in time devoted to the project in the case of NIH and DHHS awards—by the approved Project Director or Principal Investigator and key personnel.
4. The transfer, by contract or other means, of a significant part of the research or substantive programmatic effort (i.e. subaward).

Note that number 3 above does not use the term "absence" but "disengagement" from the project. The distinction is a PI/PD or key personnel can be off campus and still engaged in the research, which would not require prior written approval.

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, countersign and uploaded it into the appropriate SeRA record(s).

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.

Limitation of Funds

The Limitation of Funds clause is typically inserted into Federal contracts that are incrementally-funded cost-reimbursement contracts.  The clause requires Stanford to notify the sponsor that we are coming to an end of obligated funding, and send notification to the contract officer that the obligated funds will be fully spent within the next 60 days. OSR will initiate the notice to the sponsor.  You may also notify OSR if 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 Stanford to notify the sponsor if 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.

Although sponsors allow some flexibility with respect to re-budgeting, un-obligated balances, and pre-award costs, Stanford 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
• Disengage for more than three months or a 25% reduction in time devoted to the project, by the approved PI and/or key personnel
• Additional federal funding
• The transfer, by contract or other means, of a significant part of the research or substantive programmatic effort (i.e. subaward).

Uniform Guidance

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 and key personnel.

Note that number 3 above does not use the term "absence" but "disengagement" from the project.  The distinction is a PI/PD or key personnel can be off campus and still engaged in the research, which would not require prior written approval.

The new term "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, countersign and uploaded it into the appropriate SeRA record(s).

Example:

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.

Modifications

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 and consult your IO (institutional Official).

Getting approval for and communicating about project changes

SeRA Central Office Requests allows department administrators to submit requests to the Office of Sponsored Research (OSR), Research Management Group (RMG) and Industrial Contracts Office (ICO) via the SeRA system for institutional officials to contact sponsors for notifications, requests and approvals, or for OSR Post award Research Accountants to modify existing Oracle accounts - PTAs for sponsored projects. 

Benefits of the SeRA Central Office Request form:

• SeRA records when the request was submitted; what information was provided; who is working on it; and the status of the request and all requests are searchable
• Eliminates emails to one person and delayed response since requests are sent to the central offices' queues which allows for assignment to the next staff member if staff are out of the office.
• Users can see who the request is assigned to and the processing time to date.

Please do NOT use a Central Office Request to follow up on the status of an existing SeRA transaction (proposal, award, PTA, Central Office Request etc.).  Rather, look up the relevant transaction in SeRA to view the latest information, and, if needed, follow up with the relevant transaction’s current assignee via email.

SeRA Central Office Requests are divided into two subgroups:

• Pre Award Central Office Requests - Use when you need to tell/ask the sponsor something e.g. No Cost Extensions, Sponsor Prior Approval requests, etc.
• Post Award Central Office Requests - Use when you need to change something related to an Oracle PTA e.g. add a new task, rebudgeting within or amongst tasks that do not require sponsor prior approval etc.

Learn More

Spending Before or After the Start Date of Your Award

Federal granting agencies have delegated to Stanford the ability to initiate:

Pre-Award Costs

It is possible to spend before the anticipated award start date if the sponsor authorizes it in writing. Check the terms and conditions of the specific award for restrictions on pre-award spending. 

• Most federal sponsors allow preaward spending for grants 90 calendar days prior to the anticipated award start date.
• Other sponsors limit the dollar amount or do not allow pre-award spending. 
• Contracts do not allow pre-award spending.

If the sponsor authorizes pre-award spending, you can open an early PTA (Project Task Award). If the research involves human or animal subjects or stem cells, a protocol must be submitted before an early PTA can be opened. Although you can receive an early PTA, certification is required that protocols have been filed for review and that no expenses involving those activities will be incurred until the final protocol approval is granted. Learn how to open an early account by viewing the Sponsored PTA Manager Early Account User Guide on the ORA website.

The sponsor is not obligated to fund the pre-award costs if the project is not funded, and the sponsor's authorization of pre-award spending does not guarantee that the PI will receive the award. If the award does not materialize, the PI must cover for the costs from his or her unrestricted funds.

In addition, if the start date of the project is delayed beyond the 90 day period, the award will not cover the costs if they were incurred outside the 90 day period.