Managing an Award
Grant management involves abiding by the award terms and conditions throughout the lifetime of the sponsored project or program regarding the following:
Award expenditure monitoring
Appropriate use of expanded authorities for certain federally funded awards
Sponsor approval requests as required
Cost sharing during the award
Award continuations and renewals
A sponsored project or program expenditure must follow certain guidelines in accordance with the award terms. Guidelines and procedures exist for certain types of direct cost expenditures. See below for more information regarding each topic.
All grant/contract expenditures must be based on the cost principles outlined in the OMB Uniform Guidance. Allowable costs can be charged to the award fund; unallowable costs must be charged to the department. The following are examples of unallowable costs:
- Advertising and public relations costs
- Bad debt
- Donations and contributions
- Entertainment costs
- Fines and penalties
- Goods and services for personal use
- Housing and personal living expenses
- Pre-award costs unless authorized by the sponsor
During the course of a project, the sponsor may find it necessary to issue a modification to the original sponsored award. Many sponsored awards obligate only the first year of funding, so sponsors issue award modifications for future increments. Other modifications may be issued for such activities as decreasing funding, extending the period of performance or revising other terms and conditions of the sponsored award. All written sponsored award modifications must be directed to ORSP. It is the responsibility of ORSP to update the notice of award and distribute the modification to the PI and Department.
During the course of a sponsored project or program the PI may find it necessary to continue beyond the awarded period of performance.
A renewal is the sponsor’s authorization for additional funding, scope, and extension to an existing sponsored award. Requests should be prepared by the PI and Department and routed to ORSP as a renewal proposal. Renewal funding sometimes arrives as a modification to the original sponsored award number. When a full renewal proposal is submitted, it is referred to as a Competitive Renewal and is subject to peer review.
The National Institutes of Health (NIH) has more specific language on renewals. NIH awards continuing year-to-year are non-competitive renewals, where funding is based on NIH’s determination as to whether to provide funding for the budget period subsequent to that covered by the submitted progress report.
NIH considers any subsequent year of funding after the first authorized award year as a non-competitive renewal. This simply means that continued funding is contingent upon NIH approval of progress made on the research as reported in the Non-Competing Continuation Progress Report.
The Check Request is used by all departments to process payment for certain expenditures that do not require a standard purchase order. The types of expenditures processed on a standard check request are:
- Travel expenditures (registration fees, transportation, lodging, meals, etc.)
- Conference expenditures
- Travel advances and repayments
- Membership dues
Adequate documentation such as original invoices, original receipts and registration forms should be submitted to SPA. If approved, requests are forwarded to Accounts Payable for payment.
It is each department’s responsibility to close their encumbrances since department staff is familiar with the purpose and circumstances of the encumbrance. However, ORSP should handle purchase order activity for any subcontract or consulting agreement. Instructions for closing encumbrances can be found here.
The purpose of cost sharing is to document expenses that are in support of a sponsored program (grant/contract), but not paid by the sponsor and are mandatory to meet the conditions of the award, in compliance with Uniform Guidance.
In accordance with the University’s cost sharing policy, award monitoring of the cost sharing expenditures should be performed on a routine basis by the Department Administrator and the PI in order to ensure that cost sharing obligations are fulfilled. The Department and PI are ultimately responsible for fulfilling and documenting the cost sharing commitment proposed. If proposed forms of cost sharing are not achieved, the Department and PI must identify alternate forms of cost sharing to fulfill the obligation to the sponsor. Otherwise, a reduction in the award funding could occur.
Cost Sharing Policy
Mandatory cost shared expenses shall be documented within DU’s financial system (Banner) by indicating the appropriate activity code for each expense transaction that is in support of the sponsored program. Cost sharing on a federal award may not be paid by any other federal award (either direct or flow-through).
When a proposal is prepared, the PI shall work with ORSP to identify cost shared expenses.
When a sponsor requires cost sharing be reported on a grant, SPA will create a cost share activity code once the award fund is set up. The cost share activity code is used in Banner and Pioneer Travel & Expense to tag expenses on internal operating (10000) or designated (8000) funds.
The cost share activity code will be needed on all transactions for salaries, supplies, travel and equipment. It is not necessary to use the cost share activity code on tuition, waived indirect costs or third-party contributions.
Roles & Responsibilities
Principal Investigator: Assures that all cost shared expenses are identified and coded with the proper activity code.
Deans/Department Chairs: Assures that departmental staff who are responsible for entering data into Banner are knowledgeable about the requirements of coding cost-shared expenses.
ORSP: Codes awards with the proper cost-sharing requirements, creates activity codes, and distributes regular reports for notification of cost sharing requirements.
The University’s policy on Cost Transfers to Sponsored Program Funds ensures that incurred costs transferred from a sponsored or non-sponsored project or program award to a separate federally funded sponsored project or program award comply with sponsor terms and conditions, regulations, and University policies. The policy can be found here includes the following key points:
- Definition of cost transfer
- Procedures for cost transfers
- Roles and responsibilities
The OMB Uniform Guidance requires that each grant recipient document time expended towards a sponsored program. Recognizing the unique nature of universities and the absence of timecards, OMB requires documentation and certification of percent of effort, totaling 100%, in support of one’s total commitment to the University.
In order to meet this requirement for documentation and certification, each individual paid on a monthly basis and who has some commitment towards a sponsored program shall certify their effort based on the distribution of total compensation paid to the individual during that month. This process is done electronically, and instructions can be found here.
Commitments to match funds from external sponsors for the purpose of purchasing equipment may be made by the Department Chair, the Dean, the Vice Provost for Research or a university employee who has fiscal responsibility for university non-restricted funds. Such commitments are considered cost-sharing. Authorization from these individuals is required prior to proposing any commitments, and these individuals will need to consider such commitments in their budget planning processes.
- When a proposal is prepared, the PI shall work with ORSP to identify cost-shared expenses.
- If a match for equipment is required, the PI shall obtain commitments from the Department Chair, Dean and/or Vice Provost for Research. Commitments shall be indicated on the ORSP Proposal Review & Approval (PRA) Form by noting the amount, fund/org, expected fiscal year of expense and signature.
- Upon award of the grant, ORSP shall communicate to the PI and Department Administrator the amount that is reserved for match and the fiscal year. The PI/Department Administrator shall confirm expected purchase(s) by indicating the DU purchase order number(s) and returning to ORSP.
- The equipment shall be purchased from departmental funds.
- The department shall submit invoice(s) and a copy of financial transactions that have been paid to ORSP for reimbursement to their department fund/org.
- ORSP makes expense transfers to the appropriate FOAP.
Expenditure Documentation & Approvals
In order for an expenditure to be charged to an award fund, the expenditure transaction must include adequate documentation to support the nature of the transaction. The transaction must be certified by the Principal Investigator (PI) or Department Administrator (DA) that the expenditure is appropriate and allowable to the award. By certifying the transaction, the PI or DA is certifying that the expenditure is:
- Reasonable, allocable and necessary to fulfill the requirements of the project
- Allowable under the terms and condition of the award
- Allowable under Uniform Guidance, unless specifically allowed by the award
Please review the SPA Expenditure Documentation and Approvals Policy.
If your project requires financial reporting, please contact your Grant and Contract Administrator (GCA) to complete any necessary financial reports to the sponsor, including interim and final financial reports.
Grant Financial Reports
The Grants Inception to Date report with transaction drill-down capability can now be accessed through Data Insights.
If you have questions on using these reports, please contact your Department Administrator or your Grant and Contract Administrator (GCA) in SPA.
If you have questions on running reports or need assistance, please contact your GCA.
SPA is responsible for all invoicing, billing in Banner, and applying payments on grants and contracts. The GCA determines the type of reimbursement rate and then invoices accordingly.
- Cost reimbursable grants/contracts are usually invoiced monthly based on actual expenditures.
- Fixed price contracts are invoiced on a predetermined schedule and are not based on actual expenditures.
Once invoices are generated, they are signed for approval and sent to the sponsor.
A journal entry can be used to distribute expenses to a project such as telephone and photocopying charges that have been recorded in an administrative account. Journal entries can also be used to correct clerical and bookkeeping errors. Any transfers involving salary and fringe benefits on research accounts must be handled by ORSP.
When processing a journal entry, the following issues must be addressed:
- Justification: A detailed explanation must be provided which explains the need to transfer an expense which has previously been approved on another account.
- Documentation: There must be an audit trail traceable to the original charge
- Timeliness: Journal entries must be processed within 90 days of the date of the original charge. Any transfer request submitted after 90 days will be disallowed unless there is a justification for the delay. Journal entries submitted more than 60 days after the end of a project are disallowed unless there is justification for the change.
All journal entries are reviewed by the Project Accountant for allowability and then forwarded to general accounting. Please contact your Grant and Contract Administrator (GCA) with any questions regarding transferring expenses.
Reconciling grant funds on a monthly basis will allow you to manage your sponsored funds to ensure all expenditures and revenues are within appropriate limits and guidelines. More information on limits and guidelines can be found on the appropriate sponsor websites in the Uniform Guidance. Regular monitoring will help to:
- Minimize cost transfers
- Ensure timely and accurate effort reporting
- Verify the availability of project funds
- Avoid overspending, which may limit further funding
- Request timely sponsor approvals as necessary
Do not wait until a problem is brought to your attention or until a project has terminated before reconciling an account.
Using Inception-to-Date Reports
Principal Investigators should monitor the financial activity of their award from the day it is activated until it’s terminated. This can be done through the IBM Cognos Connection in MyDU. These reports allow users to view actual versus budgeted expenditures for an award or project to assist in continuous award monitoring. The reports also show current period expenditures and encumbrances, and can drill down to the details.
Please refer to the Payroll website for information regarding timesheets, salary adjustments, payroll redistributions and the payroll calendar. All payroll items are processed in Shared Services.
Posting Transactions to Grant Funds
Spending of any funds awarded by the federal government to the University of Denver is governed by Uniform Guidance.
For additional guidance on appropriate budgeting and expenditures of sponsored funds, whether from federal or non-federal sources and whether the award is directed toward research, training or other purposes, please see the expenditure policy.
The University of Denver is exempt from Colorado State sales tax. The University’s tax-exempt number is 84-0404231, which should be provided to vendors when making purchases that will be posted to sponsored accounts.
Although many sponsored awards allow flexibility in areas such as rebudgeting, carry forward of unobligated balances from year-to-year, and pre-award costs, sponsors expect expenditures to be reasonably consistent with the proposed scope of work and budget. Many federal agencies have chosen to delegate authority to the University for rebudgeting, pre-award costs, single no-cost extensions, etc. The Department Administrator and PI should refer to the sponsor’s award terms to determine the authorizations that apply to each award.
Oftentimes, sponsors require PIs to request prior approval for significant changes that affect the following:
- Scope of Work changes
- Change in PI effort
- Change in PI/Key personnel
- Significant rebudgeting
- Use of program income
- Other specific terms and conditions
- Transferring a substantial portion of the work
Many federal and nonfederal grants require prior sponsor approval for changes made to the terms or conditions of a grant, including budget changes. The Department Administrator and PI need to complete a Prior Approval Request Form and submit to ORSP that includes the project-specific justification and plan for the approval request. ORSP will determine if the request requires sponsor approval and forward it to the sponsor's grant officer.
Prior Approval request form
Several federal agencies have granted ORSP the authority to make certain specific decisions regarding sponsored projects. The University Expanded Authorities allows for the University of Denver to authorize certain administrative changes to a sponsored award without advanced sponsor approval. These authorizations may include:
- Allowances for 90-day pre-award costs
- No-cost extension for up to 12 months
- Minor rebudgeting between accounts
To exercise the University’s Expanded Authorities on applicable awards, the PI or Department Administrator must submit the ORSP Prior Approval Request form. Upon review and approval, ORSP will take any necessary action with the sponsor.
Review program income procedures here.
- Research Travel