At Emory University, the development, submission, and management of an award, from concept to closeout, is a shared responsibility across many units and individuals. These include, but are not limited to, the Principal Investigator, Office of Sponsored Programs, Research Grants & Contracts, and Research Administration Services.
Awards begin as concepts, concepts that are developed and funded under a sponsored agreement. The award lifecycle describes the different stages of a sponsored agreement, from conception to award closeout.
The stages are:
- Conception of Idea and Funding Opportunities
- Proposal Development and Submission
- Award Negotiation and Acceptance
- Award Management
- Award Closeouts
Award lifecycle:
The Office of Sponsored Programs and Research Grants and Contracts work closely with investigators and Research Administration Services to ensure timely, accurate award setup and to assist with award management and closeout. Services, processes, timing, and tools for supporting an award from acceptance through closeout are described below.
Award Negotiation & Acceptance
Once a sponsor approves an award for funding, they issue an award notice or execute an award agreement. Both typically result in an award document that specifies the awarded amount, award period, billing terms, required deliverables, and applicable award terms and conditions. Sponsors may also have policies and other funding regulations, such as the Uniform Guidance, NIH Grants Policy Statement, funding opportunity announcements, etc. that apply to how award funds are managed. In addition to Federal and sponsor regulations, Emory University also has policies and procedures that must be followed.
Upon receipt of an award notice/agreement, the award terms and conditions are reviewed by OSP staff who are skilled in vetting award notices to ensure the University and investigator can comply with all the associated terms and conditions. Authority for accepting award terms and conditions resides with OSP staff. Once an award is accepted, it will be set up in the Compass financial system utilizing the proposal record routed at the time of application submission or contract negotiation. Typically, an award in COMPASS has several projects and related SpeedTypes, which are used to incur expenditures and other transactions related to the award. Budgets are created in Compass based on the awarded amount. If the awarded amount differs significantly from the proposed amount, OSP may need to request a modified budget or may need to work the PI and sponsor to negotiate the budget and scope of work
Creating an award involves several offices, including the Office of Sponsored Programs (OSP), Post Award Setup (PAS) in Research Grants & Contracts (RGC), and Research Administration Services (RAS). The time from receipt of an award document to set-up will vary based on the complexity of the award and a number of others factors (compliance requirements, etc.), and can range from a few days to several weeks from receipt of the award until all steps are completed and the related SpeedTypes are released and available for use. Depending on the specifics of the award or status of compliance requirements, other offices, such as the Research Compliance and Regulatory Affairs (RCRA) may also be involved during the award set up and may affect the set up processing time.
Award Management
Once an award has been set up in COMPASS, the PI can begin working on the project and incur commitments and expenditures. If funding is imminent and a COMPASS award is needed prior to receipt of an award notice/agreement, a Provisional Award Number (PAN) can be requested, and upon approval, a COMPASS SpeedType can be created for the PI to begin work and incur expenditures.
Proper award management throughout the life of the award is key. Award management encompasses practices based on the sponsor’s policies, award terms and conditions, as well as the University and schools’ policies. Proper award management starts with the award proposal by creating a budget and budget narrative that is not only in line with the sponsor’s requirements, but also based on reasonable expectations of expenditures.
Award management includes:
- Award monitoring: This is a key component of award management and includes regular and timely award reconciliations and budget-to-actual reviews to ensure that the award burn rate is as expected. Your awards are reconciled by the post award team in RAS, who will provide you with updated reports for your review. In addition, financial information is available on-demand through the PI Financial Portal. Information on using the PI Financial Portal is found under Faculty Reports on the EBI webpage.
- Reporting: Reporting is another critical component of award management and includes effort certification, programmatic, financial, and any other required reporting.
- Effort Certification: This is a process where you confirm the proportionate amount of time spent on each activity (e.g., an award is considered one activity) and that the salaries charged are reasonable in relation to that activity. Emory University has two effort periods: September 1st through February 28/29 and March 1st through August 31st and effort certification is due within ninety days of each period. Effort not certified timely is considered unallowable so it is critical to certify all effort timely.
- Programmatic reports: Depending on the award, the format and details included in programmatic reports will vary. For example, federal awards typically require an annual Research Performance Progress Report (RPPR) and a Final RPPR at the end of the project. Timely reporting is a condition of the acceptance of an award, and failure to comply may seriously affect future funding.
- Financial Reports: Similar to programmatic reports, details and format on financial reports vary, but federal awards typically use the Federal Financial Report (FFR). While most financial reporting is currently done by RAS and RGC, some sponsors may require these to be submitted by the PI. These instances are rare, and you will be prompted when your assistance is required.
- Billing: Depending on the award, billing could be based on expenditures incurred or milestones reached. Timely and accurate posting of expenditures is critical and will affect cost reimbursable invoices. Timely completion and submission of required milestones will result in proper and timely billing when the billing is driven by delivery of milestones.
- Award Modification: Unexpected or unplanned changes may result in award and budget modifications. These modifications may require prior approval from the sponsor, so communicate the need for modifications early.
Effective management is critical in maintaining the public’s trust in research at Emory University. To successfully manage an award and be compliant:
- Ensure that personnel on the project is aware of its responsibilities and those of the University’s academic and administrative offices.
- Abide by the terms and conditions of the award, such as required prior approvals, reporting, and approved scope of work.
- Understand the sponsor’s and University’s policies and work with RAS for guidance.
- Contact your RAS pre-award office if you need sub-awards to be written to other institutions on your project.
- Understand that cost-sharing is subject to the same rules as sponsors’ funds and must be accounted for in a similar manner.
- Ensure that charges to sponsored awards benefit the award charged. For example, it is not appropriate to average the costs of research supplies across all your grants, regardless of how the supplies are used. Since the charges must benefit the award, large purchases towards the end of an award may be frowned upon and must be minimized. Cost charged to a sponsored project must be necessary, reasonable, and allowable. The University is audited on whether it treats similar costs in consistent ways across the institution. Administrative costs, office supplies, or telephone equipment, which are included in our indirect cost base, cannot be charged directly except with non-federal sponsors.
A Special Note on Clinical Trials
Funding of industry sponsored clinical trials is based on the protocol and enrollment of the trial. Payment is typically driven by milestones (startup, accruals, procedures, etc.) and tends to lag activities and related expenditures incurred. Proper award management requires expenditures to be posted when activities occur (e.g., charge salary expense when effort is spent) rather than when cash has been received. The Office of Clinical Research (OCR) assists with guidance, billing, and compliance with management of clinical trials.
Award Closeout
Email notifications are now generated and sent to the PI 90, 60, and 30 days prior to the project end date as a reminder of the upcoming expiration date and as a trigger for a no cost extension request or contract modification, if needed, to complete the work. A final notification is also sent out upon expiration of the award.
Prior to the closeout, the PI and RAS/ departmental designee are expected to review the project, clear out all outstanding encumbrances, and determine if all expenditures are posted. No new charges or commitments may be incurred to a project after the project end date. This includes personnel charges.
Charges that were committed before the project end date may be processed after the end date; however, they must be paid prior to the final financial report, or invoice will be prepared based on Emory University’s internal deadlines for award close out, the sponsor regulations, and the award document.
Projects will be closed out in accordance with the Closeout Policy. The PI and/or other personnel will contact RA to determine if there are residual balances.