Post Award Management
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- If the protocol involves human subjects, it must be approved by the University’s Institutional Review Board (IRB). Please go to the website for further instructions.
- If the protocol involves vertebrate animals, it must be approved by the Institutional Animal Care and Use Committee (IACUC).
- If the protocol involves hazardous material, it must be approved by the Institutional Biosafety Committee (IBC). Please go to the website for further instructions.
These approvals must be received by OSP in form of an Approval letter by the committee or an email by the Chair of the Committee (IBC only).
Until approval receipt, you will be unable to start your project, so please start the necessary process as soon as you have received an indication of strong potential for award by the Sponsor.
Post Award Management Responsibilities
A. Principal Investigator
The Principal Investigator (PI) serves as the primary individual responsible for the scientific integrity and fiscal and administrative management throughout the period of the award. The PI's specific responsibilities include:
- Being cognizant of, and adhering to, all sponsor-imposed terms and conditions, as well as University policies and procedures related to administering sponsored agreements. (This includes all relevant government and University regulations regarding the use of human and animal subjects, biohazards and bio-safety, occupational health and safety, conflicts of interest, and purchasing and equipment management policies.)
- Obtaining prior approvals from the Office of Sponsored Programs (OSP) or working with OSP to request prior approval from the sponsor for post-award changes relating to the conduct or scope of the work, and/or budget amendment, expenditure of funds awarded.
- Observing TUC policies and procedures to protect intellectual property rights and academic freedom.
- Supervising project personnel including co-investigators, post-doctoral associates, and students (both graduate and undergraduate).
- Submitting technical/programmatic progress reports in a timely fashion to the sponsor as required by the terms and conditions of the award.
- Managing and controlling project funds in a prudent manner and expending funds in accordance with the restrictions imposed by the award terms and conditions and University policy. Funds should only be expended to directly support the project effort and expenditures should not exceed the total amount of funds awarded. Deficits and disallowances incurred against an extramural award account/fund are the responsibility of the principal investigator.
- Advising OSP of any cash collections issues or any other information on the financial instability of the agency as soon as they are aware of these issues.
- Advising OSP of changes in key personnel specified in the application or award document, (reduction in time and/or absence from the project of key staff, e.g. the PI.)
- Ensuring that all requests for no-cost extensions are filed on time with OSP.
While responsibility for certain day-to-day management of the project finances may be delegated to administrative or other staff, accountability for compliance with the sponsor requirements and University policy ultimately rests with the PI.
Chronic failure to carry out the responsibilities incumbent upon a principal investigator or chronic noncompliance with sponsor regulations, can result in nonpayment of University invoices. Ultimately, this might jeopardize future funding to the PI, as well as to the University as a whole.
Helpful Suggestions for the P.I.
- Do not incur obligations under new or renewed projects until authority to expend has
been received and an appropriate account number has been assigned.
- Read the award guidelines and budget carefully to ensure proper management of the
- Do not purchase equipment during the last three months of a federal grant. Federal
auditors may disallow the cost of the equipment purchased near the end of a grant.
- Under ordinary circumstances, PIs should not order supplies during the last month
of a grant.
- Verify all charges on the grant with the Grants Manager before such financial commitments
are made. Common budget items and recurring expenses, such as salaries, should be
verified when the account is established.
- Process all budgetary adjustments through the Business Office to avoid audit dis-allowances.
- Each month monitor the grant expenses and encumbrances as a check on the remaining
- Do not make expenditures on a terminated grant account while awaiting assignment of
a new account number for a renewal grant.
- Do not incur obligations if you have any doubts as to whether they will be allowed.
Always check with the agency contact for your award and with the Grants Manager.
- Make a point to submit required periodic and final reports on time.
- Remember that the Grants Manager (OSP) has fiscal responsibility to ensure that your
award is administered in accordance with the regulations of the funding agency and
the university. Do not circumvent standard university procedures for any reason.
- All grant-funded faculty salary items should follow the normal process: obtaining
approval by the department head, designating the charging of the correct salary amount
to the grant account, and forwarding to the Grants Manager for final approval and
payment processing. Be aware of required salary fringe benefits that apply to faculty
- Any expenses in excess of individual budgeted items or the total grant award will be charged to the P.I.’s Indirect Account.
The Office of Sponsored Programs
The Office of Sponsored Programs (OSP) at Touro University California (TUC) is responsible for preparing, interpreting, negotiating, and accepting agreements for projects funded by federal, state, and local government agencies, foundations, corporations, and other public and private sources. OSP also prepares and negotiates all sub-awards for collaborative research. OSP's specific responsibilities during the post award management process include:
OSP is responsible for the overall administration of the award. The Principal Investigator (PI) not only is the primary individual responsible for scientific integrity, he/she is also responsible for the fiscal and administrative management of the project. OSP will assist the PI in these duties. OSP's specific responsibilities include:
- Communicating frequently with principal investigators to keep them apprised of the project's financial business developments and assist them in the administration of awards.
- Providing principal investigators with business and accounting expertise.
- Ensuring that the award's budget in Banner reflects the terms of the agency approved budget.
- Reviewing project expenditures including overhead charges on a regular and timely basis, usually at least once a month. Ensuring the accuracy of overhead charges.
- Reconciling project ledgers on a timely basis and reviewing project financial transactions with the PI (when necessary).
- Ensuring that project expenditures are charged in accordance with the terms and conditions of the award and/or University policy. If the direct expenditures of project funds are for costs that would normally be charged indirectly, e.g., clerical and administrative expenses, postage, office supplies, local telephone calls, general-purpose equipment, or operations and maintenance, then those items must have been supported in the proposal by an explicit budget justification and must be included in the final budget awarded by the agency. These direct charges will be allowed only upon sponsor approval. In addition, when administrative and clerical costs are being proposed to a federal sponsor, the proposal must have included an explanation of the activities that allow the project to be classified as a "major project". The proposal must have an explanation of why the charges would be applicable to the project, NOT why the project is a MAJOR project.
- Reviewing ledgers for unallowable costs posted to the fund throughout the project period and promptly transferring any unallowable charges to an appropriate fund outside of the award. Any questionable charges must be brought promptly to the PI's attention, and, if needed, corrected by an appropriate cost transfer. Transfers should be initiated as soon as possible after a need has been identified. Whenever expenses are moved to or between sponsored award accounts, the PI must assure that the project which ultimately pays the expense is the project which benefited from that expense, and that there is adequate documentation to support the appropriateness of the transfer.
- Ensuring that the project complies with all appropriate University payroll, reimbursement, accounting, and personnel policies and practices.
- Monitoring encumbrance balances on a monthly basis and ensuring the balance reflects current purchase obligations for the award and that PO's are closed out on a timely basis.
- Providing PI with regular accounting reports of project balances and expenditures, as well as projections of future expenditures.
- Assisting PIs with all administrative aspects of an award, including maintenance of internal records related to project expenses, activities and reports.
- Ensuring that the PI has approved all appropriate transactions (e.g. cost transfers) in accordance with University polices.
- Ensuring that the percent of salaries charged corresponds to actual time spent on the project.
- Ensuring that effort reports are completed on time and certified by the appropriate official with first-hand knowledge of the work performed.
- Ensuring that the project operates in accordance with its budget. If required, assisting the PI to prepare budget amendments for sponsor.
- Preparing "Invoices" and billing on non-federal awards that require detail expenditure information for the sponsor in accordance with the award invoicing terms.
- Providing the sponsor with detail expenditure support documentations as outlined on the signed contract, in order for the sponsor to release payments on University invoices.
- Ensuring that all cost share forms are prepared and copies forwarded to New York Accounting for further processing and monitoring at award stage.
- Advising and assisting the PI in fulfilling the award closeout requirements. Working with New York Accounting for the final financial report to the sponsor.
- Ensuring transfers of any overdraft amounts resulting from unusual circumstances or unanticipated project expenses to the appropriate source of funds is promptly completed prior to close out of the award.
- Ensuring that the project records are kept in good order and are readily available for review and audit.
- Assisting internal and external auditors if required.
Timelines for Selected Activities
Federal Uniform Guidance
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