How to Manage Your Sponsored Awards

Purchases cannot be initiated until a budget is created and the Principal Investigator/Project Director is notified it is appropriate to begin expending.

Expenses are charged to sponsored award budgets the same as they are charged to any Fairmont State budget and as such must conform to State and University procurement policies and procedures, unless otherwise authorized by the OSP.

All costs charged to a sponsored award budget must be reasonable, allocable to the specific project, consistent with the way costs are treated in like circumstances at the University, and allowable under applicable sponsoring agency guidelines as well as state and federal policies and procedures.

Items charged to award budgets are to be utilized only for the purposes of the grant project and used during the grant award period. Therefore, “last-minute” purchases to use up funds will not be permitted. Very few purchases are considered allocable during the last few weeks of a grant period. The PI will be responsible for monitoring and reviewing the award budget in the Banner/Felix system on a regular basis to ensure posted expenses are accurate and inclusive. The PI will be sent a monthly budget report to review and approve the project budget and all expenses.

All expenditures should be processed well in advance of the last 30 days of a grant period. All expenditures must be processed, items received, and charges posted to the award budget before the end-date of the award.

Participant Support Costs

A participant is an individual participating in or attending program activities under a Federal award who is not responsible for the implementation of that award. Individuals delivering or developing program activities, such as consultants, project personnel, and recipient or subrecipient staff members, cannot be considered participants. Participant support costs refer to direct costs that support participants and their involvement in a Federal award. Examples include stipends, subsistence allowances, travel allowances, registration fees, temporary dependent care, and per diem paid directly to or on behalf of participants. Funds provided for participant support may not be diverted to other categories of expense without the prior written approval of the agency. Since participant support cost is not a normal accounting classification within the University's finance system, the PI must be able to separately identify participant support costs by maintaining a shadow budget and all related documentation to support expenses. The PI is required to submit a copy of the shadow budget to OSP at the end of their award period yearly.

Grant-related expenses should be charged directly to the Fund/Org assigned to the grant award budget and posted to the appropriate account code. Transfer requests are considered irregular activity and should be a rare occurrence, not the norm. Expense transfer requests require justification, review, and approval. PIs are responsible for monitoring their award budget in the Banner/Felix system on a regular basis to ensure posted expenses are accurate and inclusive.

If an expense is mistakenly charged to an incorrect budget, PIs should work with their staff person to get it corrected quickly. The Grants Transfer of Expense Request form must be completed. The PI must sign off on the form and have it sent to the Office of Sponsored Programs (OSP) for approval. Once approved, the OSP will forward the form to the Accounting Office for processing.

The PI must work through the OSP for any and all budget changes. Once the OSP agrees that a budget change is needed, the OSP will contact the sponsoring agency asking for their approval or will give permission to the PI to make the request to the agency themselves.

All expense transfers should be approved and processed within 30 days after each PIs monthly review of expenses, and well in advance of the last 30 days of a grant period.

Following is a quick reference list for some types of unallowable expenses. The sponsoring agency may have additional restrictions which should be noted on the award document. PIs should contact the OSP for any questions that they may have.

Alcoholic Beverages

Alcoholic beverages are unallowable, including beer, wine, and mixed alcoholic drinks. Alcohol can be directly charged to a sponsored project only if the nature of the research specifically requires the purchase and use of alcohol and the sponsor explicitly approves the cost.

Clerical/Administrative Salaries

Administrative and clerical personnel provide non-technical support services that benefit departmental or institutional activities. Services provided by these staff members may include: clerical support, budget management, procurement of materials and services, and personnel processing. The scope of duties is the same regardless of the type of budget or program/project involved and duties are expected to be completed during the regular workday time period. Therefore, additional payment or stipend for these duties is unallowable.

Computing Devices

Computing devices are generally considered unallowable and are expected to be purchased with school and/or departmental accounts and considered a general office item. Computing devices that cost less than $5,000 and are essential and allocable to the performance of an award (as determined by the Office of Sponsored Programs) may be charged directly.

Copier Charges

Routine copying charges fall under general administrative support of a project and should not be charged as a direct expense.

Entertainment

Costs of activities where the primary purpose is amusement, diversion or social activities, and any expenses directly associated with such costs, such as tickets to shows or sports events, meals, lodging, rentals, transportation, gratuities etc. are unallowable.

Memberships, Subscriptions and Professional Activity Costs

Membership and subscription costs must not be directly charged to sponsored agreements. Membership in any civic or community organization, or in any country, social or dining club is always unallowable.

Postage

Costs incurred for freight or postage and other transportation services relating either to goods purchased, in process, or delivered, are allowable. When such costs can readily be identified with the items involved, they may be charged directly as transportation costs or added to the cost of such items.

Outbound freight or postage such as letters or mailings is typically treated as an F&A expense and is not allowable.

Supplies

General office supply items used for day-to-day office and work functions are unallowable. These items may include pens, tablets, staples, staplers, post-it notes, tape, file folders, binders, toner cartridges, printers, thumb drives, cleaning materials, wall clocks, calendars, waste cans, paper punches, University stationery, etc.

Program supplies used directly in support of the project/program are allowable. These may include laboratory supplies, lab materials, plotter pens, lab notebooks, and other items that have a more specific function, can be directly associated with a project, and will likely be consumed in the course of the project.

Telecommunications Expense

Basic local telephone services on campus, including phone installation, monthly line charges and internet charges, and cellular phones are unallowable.

If you want to spend grant funds on items that are not included in your awarded budget (or alter the grant terms), check with the OSP before initiating these expenditures; most often, these expenditures will not be allowable. The OSP will review the request, communicate with the sponsoring agency (if needed), and notify you if you can proceed. Budget changes that require sponsoring agency approval include line-item changes, those that may violate sponsor policies, or those that change the scope of the project.

If there is a cash cost-share commitment, a separate matching funds budget will be established. Please ensure expenditures are split between the award budget and the match budget according to the award specifications. It is necessary to accurately code expenditures so the financial reports will appropriately reflect the cost-share commitment.

If there is an in-kind cost-share commitment, it is crucial that the PI maintain detailed records to provide evidence that can be included in the report provided to the sponsoring agency.

Faculty

Faculty who serve as PI may be compensated if allowable and approved by the sponsoring agency. Compensation may be in the form of a reallocation of workload (buy-out) or a stipend for additional work performed. The award may require hiring of personnel who work only for the grant project and are funded 100% by the grant budget. The award may also include stipend payments to other Fairmont State personnel who contribute defined duties and deliverables to the grant project.

Students

Student worker wages are established by Human Resources, not by the approved grant budget. A regular student worker usually works for an extended period of time and is responsible for completion of routine, general duties. Students are usually paid on a Temporary Appointment form if they work a short time period and are tasked with completing complex assignments unique to the grant project.

Change in PI or Other Key Personnel Changes

Any proposed changes to the PI or other key personnel should be discussed with the OSP well in advance of initiating these changes. If unexpended issues occur, please contact the OSP as soon as possible to resolve any difficulties which might arise. The OSP may be required to secure approval from the sponsoring agency before formalizing any changes.

Effort is defined as the amount of time spent on a specific project in relation to an individual’s full University workload and is expressed as a percentage. A full University workload includes all activities that are specifically related to an individual’s professional appointment at Fairmont State University. By definition, an individual’s full University workload always equals 100%—never more nor less—regardless of the number of hours worked or the appointment percent.

Effort reporting is required of all individuals listed as “key personnel” on a federally funded project (whether faculty, staff, or volunteers), as well as any other individuals who expend a significant amount of effort on the project. These individuals must report their project activities on a quarterly basis and certify them using the University’s Effort Reporting Form.

Percent Effort/Person Months Interactive Conversion Table

Instructions: Insert the percent effort or person months that you want to convert into the appropriate field.

9 Month Academic Year

12 Month Academic Year

Summer Months Are Based on the Number of Months Worked in the Year.

• If the faculty is working only one summer month, each month of effort is equivalent to 1/10 of their effort = 10%.
• If the faculty is working two summer months, each month of effort is equivalent to 1/11 effort = 9%.

Some awarded budgets include funds that will be awarded to another agency or institution. The agreement between the prime awardee and the other agency/institution surrounding these funds is classified as either a subaward or a contract.

A subaward is a formal, legal agreement between Fairmont State University and another agency or institution that is made for the purpose of carrying out a portion of an award and creates a Federal assistance relationship. The OSP manages the process of issuing this type of agreement.

A contract is a formal, legal agreement (WV-48) between Fairmont State University and another agency or institution for the purpose of obtaining goods and services for the University’s own use and creates a procurement relationship. The Procurement Office manages the process of issuing this type of agreement.

Funds that are budgeted for subaward or contracting agreements may not be reallocated for another grant's use without sponsor approval, and any subaward not included in the original budget must also be approved by the sponsor. All payments to subawardees agencies/institutions must be approved by the PI and the OSP before being processed by the Grants Accounting Office.

The OSP evaluates each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward and monitors the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. OSP performs these actions in compliance with 2 CFR 200.332 (b) and (d), respectively.

The PI is responsible for all narrative or technical reports. Be sure to check the specific terms and conditions of your grant award to be aware of what is required and deadlines for submission. Send a copy of your report to the OSP well in advance of the deadline date so it can be reviewed prior to submission. The OSP will review the report and you will be provided with feedback and/or approval before the report can be submitted to the sponsoring agency.

The Finance Department prepares all financial reports required by the sponsoring agency. Do not provide any financial information to a sponsor unless it has been verified and approved by the OSP.

Expenditures during the final 90 days of the grant period should be carefully considered. “Last-minute” purchases and expense transfers will be closely observed. If posted expenses are excessive or inappropriate, they will be reviewed and may be transferred to your department budget.

If cost overages occur, your department budget will be charged for the excess expense. If your expenses are projected to exceed the award budget, consult with your Department Chair, Dean, or Supervisor about possible funding sources to cover the additional expenses.

A project may be terminated prior to the original end-date of the grant award. Possible reasons for early termination include: the PI has expended all of the awarded funding in compliance with the award terms and conditions, and has submitted all project deliverables; the PI is leaving Fairmont State and the project will not be reassigned to a new PI; or the sponsor has requested an early termination.

Sometimes award agreements include information for how an early termination situation should be handled, so individual awards should be reviewed for specific guidance. Generally, sponsor-initiated notices will be sent to the OSP and the OSP will inform the PI. If the PI has expended all funds and met all award obligations before the end-date, the PI should inform the OSP and the OSP will act to close out the award. If the PI is leaving Fairmont State, the PI should inform the OSP as soon as possible so discussion can begin on how the award is affected and work to resolve the situation.

NOTICE: In the event of early termination, all required reports must still be provided to the sponsor.

Some sponsoring agencies allow the grant termination date to be extended if you need more time to finish the project. If no-cost extensions are allowed, you generally must be able to show that you need additional time to achieve your original goals and objectives. In all cases, such extensions must be requested well in advance of the approved termination date. Contact the OSP as soon as possible if you an extension is needed. The OSP will work with you to gather information and then the OSP will submit the request to the sponsoring agency.

As a grantee or contractor, Fairmont State University is responsible for retaining records related to a sponsored project award. Records related to sponsored projects are retained in accordance with sponsor requirements. Most records produced under Federal, State or other granting agencies have specific retention period expressed in the contract. Those grant requirements must be adhered to even if they are longer than the normal University retention period. Please refer to the specific award terms and conditions which may vary.

The Office of Sponsored Programs (OSP) is the official custodian of the non-financial grant related records, including non-funded proposals. Non-Financial Grant Records to be retained by OSP include final proposals and related correspondence, including notice of award or declination (both funded and not). Post-award documentation may include project summaries, grant authorizations, contract documents; project budget change and adjustment forms; subcontracts or sub-award agreements; grants and contracts monthly budget summary statements; patent/invention reports; related documentation and correspondence; grant change request form; no cost extension; final programmatic reports.

The majority of sponsored projects have legal requirements as to how long project records, particularly financial records, must be retained. These guidelines recognize these legal requirements as well as the substantial physical and fiscal resources required to retain technical, clinical, financial or other project records.

Instructions

1. Original records
   1. If original records are paper, electronic versions may be substituted provided that they are subject to periodic quality control reviews, cannot be altered, and remain readable.
   2. University central offices maintain official records (including proposals, awards, financial transactions, invention disclosures, and others). However, program records are maintained by PIs, and departments hold some source records and details related to the official records.
   3. Be aware of confidentiality and inclusion of personal or proprietary information in the records. Use limited-access storage for documents containing personal, proprietary or confidential information.
2. Technical/Program records are retained by the PI.
   1. Retain progress reports and final technical reports for at least 3 years after submission to the sponsor. Refer to your specific award terms and conditions which may vary.
   2. Retain the original data and all project records. After the required retention period, the principal investigator may make the decision to retain the records or to discard them when the records are determined to be no longer useful for research or educational purposes.
   3. Retain clinical study data in accordance with the clinical study agreement.
      1. Review the clinical study agreement for a provision specifying the required period of retention for source documents. The requirement may differ based on the type of study and other factors.
      2. For clinical studies involving children, records are to be retained indefinitely.
      3. In the event of faculty transfer, clinical study data must remain at the University.
3. Fiscal records are retained by University central offices but departments may have source records that support the transaction records.
   1. Federal awards: Federal record retention requirements can be found in Subpart D § 200.333 of the Uniform Guidance which states "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient."
   2. Local government awards: Review award terms and conditions. It is recommended that all records for projects funded under State awards (MOU's, grants, agreements) be retained for 6 years.
   3. Other awards: Review award terms and conditions and sponsor policies. If the sponsor or award document does not specify a specific time period to retain project records, follow the Federal requirement and retain records for 3 years after final payment under the award.
4. Guidelines for discarding and destroying records
   1. Shred paper documents containing personal, proprietary or confidential information, using a cross-cut shredding device or deposited in the University’s approved contracted secure shredding containers provided in each building.
   2. Electronic data must be securely removed from any disk, tape, USB drive, hard drive, photocopier, facsimile machine, or other device with electronic storage before the device is transferred or discarded. Deletion of an electronic record may not eliminate all remnants of the record. Contact the Dept. of Information of Technology for advice.