The process of managing sponsored research funds is a shared responsibility among the PI, the College or Department Research Administrator, and GCA; each has unique areas of primary responsibility.
The Principal Investigator (PI) has primary responsibility for management of the project within funding limitations: adhering to reporting requirements; ensuring that the sponsor will be notified when significant conditions related to the project status change; following award terms and conditions; hiring, training, and managing project personnel; directing technical aspects of the project; and coordination with departmental personnel to define administrative support. UNT also requires all PIs to review their obligations for stewardship of sponsored funds and compliance with applicable regulations, including cost principles as defined by UNT Policy and the federal government in Code of Federal Regulations (CFR) 2, Part 200 of the Uniform Guidance.
The college/department research administrator (CRO/DRA) and other college department staff play a key role in the financial management of a project, acting as a liaison between the PI and GCA. While the university places the prime responsibility for the conduct of the sponsored projects in all aspects on the Principal Investigator, the CRO/DRA and the other staff are involved in the day-to-day operations of the project. Therefore, it is imperative that the PI and the CRO/DRA interact closely and frequently to review and discuss financial and administrative matters.
Although responsibilities can vary by department, typically their responsibilities include:
GCA acts as the primary administrative liaison between PI, sponsors, and other University central administrative offices. The primary responsibilities of GCA during the post-award phase of a sponsored research project include:
Sponsor award notifications can take many forms. These documents require review and signature by the authorized institutional authority to sign on behalf of UNT. Authority to accept awards has been granted by the Board of Regents and the President to the Vice President and Associate Vice President of the Office of Research and Innovation, and such signature authority delegated to the Associate Directors of GCA. If the PI receives a notice directly, GCA should be immediately contacted. Many awards received require both sponsor and University signatures. PI’s are not authorized to sign award documents on behalf of UNT.
Upon receipt of a fully executed award document or executed contract, GCA assigns a Proj ID number and notifies the PI, Chair, Dean, and College/Department Research Administrator and provides a copy of the award agreement which includes sponsor terms and conditions and sponsor approved budget.
If a project needs to be started prior to the receipt of formal sponsor notification, a Proj ID number may be requested from GCA by submitting a completed and signed “At Risk Account” (ARA) form previously called a Departmental Commitment Agreement (DCA), along with a pro-rated budget for a period of 30, 60, or 90 days. If the award is not ultimately received or if sponsor terms and conditions disallow any expenditures incurred during the ARA period, the Principal Investigator and/or the authorized signatories on the ARA form are responsible for covering any unreimbursed expenses.
Once a Proj ID has been established, project expenditures can begin. Charging expenses to a sponsored project is initiated by the PIs or other person authorized by the PI to spend funds. Expenditures must be consistent with award requirements and purchasing procedures.
BSC must be notified prior to purchase of equipment on a Proj ID of $25,000 or greater. PPS is responsible for the bid process as required by federal and state purchasing guidelines.
Capital equipment is defined by the State of Texas as any single item costing $5,000 or greater. Multiple items of lesser value that are added to another piece of equipment are also considered capital equipment if the combined cost is over $5,000. The federal definition of capital equipment is an item costing $5,000 or more and with a useful life of more than one year. General purpose equipment and all items over $5,000 need to be specifically identified in the budget (general purpose items are things used for purposes other than scientific research). Equipment is typically not included in the modified total cost base thus indirect cost is not allowed.
The UNT Asset Management Office tracks and reports capital equipment purchases in accordance with state and federal guidelines and assists the PI with disposition of federally purchased and owned equipment in accordance with Uniform Guidance (2 CFR Part 200).
An electronic e-Par must be submitted to pay personnel from a Proj IDs. The e-Pars are typically submitted by the departmental administrator upon request from the PI. Typically, only positions listed in the sponsor approved budget can be paid from a Proj ID.
Sponsored projects should be charged with a portion of each employee’s salary equal to the effort devoted directly to that project. For faculty with nine-month appointments, one month of effort is one-ninth of the academic year salary. Sponsor funds may not be used to pay a PI above the full-time base salary. Fringe benefits are budgeted as an estimated percentage of salaries but are charged directly as an actual expense.
Most sponsors provide compensation for faculty with nine-month salary bases during the summer months at their regular monthly salary rate when included as part of the sponsor approved budget. Submission of a proposal that includes summer salary does not imply a University commitment to pay such salaries in the event the proposal is not awarded.
Per U.S Office of Management and Budget’s Uniform Guidance, 2 CFR 200.474(a), travel Costs for our Federal Awards are defined in the as “the expenses for transportation, lodging, subsistence, and related items incurred by employees who are in travel status on official business of the non-Federal entity.”
Uniform Guidance requires that we apply our policies and procedures consistently to both federally-funded and other activities of the university. As a result, travel requests and reimbursements for sponsored projects are processed in accordance with University travel procedures as defined in Travel Policy 10.049 and in the University of North Texas Travel Guidelines.
While federal and most non-federal sponsors require that travel be in accordance with the recipient (UNT) travel policies, it is important that you review the specific terms and conditions of your award and the corresponding sponsor guidelines to ensure that you are in compliance with their requirements. Certain awards may be more restrictive and may require specific sponsor prior approval, even when included in the proposal budget.
When determining whether or not and travel charges are allowable, the University of North Texas considers the following factors:
Traveling abroad on federal awards must comply with the Fly America Act and the Open Skies Agreements. To assist in that process, please look at the procedures on the Grants and Contracts Administration website.
A consulting agreement is required in most cases and is always required by federal sponsors. Such services are approved on a case-by-case basis provided that the charges are reasonable, and a selection process has been employed to secure the most qualified individual available. Payment for consulting services may be charged to sponsored projects if allowed by the terms of the specific award and UNT policy. Payments can only be made for work completed and must be supported by a Consulting Agreement and by an invoice signed by the consultant for the work performed.
UNT employees should not be paid as a consultant. Special exception may be specifically authorized when the sponsor approves the payment, the employee is from a different department or involves a remote operation, and the work is performed in addition to regular duties.
Many federal agencies have waived approval of certain post-award changes under “expanded authorities” granted to the local institution. These expanded authorities do not apply to contracts. However, grantees must still assure proper stewardship over these funds and that all costs are allowable, allocable, and reasonable.
Many federal agencies, universities, and hospitals participate in the FDP. As a participant in the FDP, UNT receives the most favorable grant terms and conditions from FDP participating federal agencies. The award notice will specify whether the project is covered under the expanded approval authorities granted under FDP.
Most federal grants permit the incurrence of pre-award costs, and UNT permits pre-award expenditures that conform to UNT’s cost transfer policy. If the PI needs to commit funds or order equipment within the ninety (90) days preceding the award start date, an “At Risk Account” (ARA) form for pre-award spending may be submitted to GCA. Upon verification of the expected award (and if allowed by the sponsor), a Proj ID number may be assigned by GCA. However, if the award funding is not ultimately received or if sponsor terms and conditions disallow any expenditures incurred during the ARA period, the Principal Investigator and/or the authorized signatories on the ARA form are responsible for covering any and all unreimbursed expenses which posted to the Proj ID.
Uniform Guidance (200.308) allows federal agencies to waive the written prior approval requirement for a One Year, No Cost Extension for Federal awards. Most federal agencies allow the sponsored project office, at UNT it is Grants and Contracts Administration (GCA), the authority to extend a project for up to 12 months, for a first One Year No Cost Extension. These sponsors usually include NSF, NIH, NASA, Department of Energy and EPA. All federal agencies however, expect institutions to verify that the scope of work is unchanged and the extension is not being requested merely for the purpose of using unliquidated balances for these first One Year No Cost Extensions. The approval of a first One Year No Cost Extension therefore requires the submission of a justification to GCA. The justification should identify the completion of the remaining project objectives and include an explanation of how the remaining funds will be spent. These first One Year No Cost Extension requests should be submitted by GCA, and require a response from the federal agency before the extension of the award can be processed.
Subsequent extension requests and all other non-federal No Cost Extension requests require sponsor approval and should be submitted through GCA. The request should be in writing, provide a justification related to the completion of the remaining project objectives, and include an explanation of how the remaining funds will be spent. The justification should not indicate a change to the scope of work and the extension should not be requested merely for the purpose of using unliquidated balances for a No Cost Extension. Additional information may be requested for subsequent federal award or other non federal award No Cost Extension requests, based on the specific award. All No Cost Extension requests should be submitted to GCA at least 60 days prior to the expiration date of the award, although some federal agencies may request an earlier submission.
Occasionally, a project’s financial resources need to be reallocated due to the nature and progress of the research. For example, a piece of equipment may become unnecessary, while another expense becomes necessary, or the scope of the project might change due to unforeseen circumstances. In these cases, re-budgeting may be required.
Re-budgeting will be allowed only to the extent the terms of the award or contract allow it. Therefore, before any attempt to re-budget, the PI should review the terms of the specific award. The PI should also assess the potential impacts of the proposed re-budgeting (e.g., shifting an expense from one budget category to another or shifting expenses from direct costs which may result in adjustment to the F&A cost collection). Depending on the terms of the agreement, re-budgeting may require sponsor approval.
Sub-awards are negotiated by RCA and are typically written as cost-reimbursable with detailed invoices required. UNT typically assesses indirect cost on the first $25,000 of a sub-award. Sub-awards usually comply with all terms and conditions of the prime award. After the sub-award agreement is fully executed and work has started, it is the PI’s responsibility to:
When the sub-recipient submits an invoice for reimbursement, the invoice must be signed by an authorized official of the sub-award entity. Final invoices should be received from the sub recipient within 30 days after the sub-award end date.
A cost transfer is any adjustment or transfer of expenditure to/from an externally funded contract or grant. Cost transfers include reclassification of salary, wages, and other direct costs (goods and services and travel). Diligent review of financial records should prevent the necessity for cost transfers; however, transfers may be appropriate under certain circumstances.
Costs directly charged to sponsored awards must comply with the cost principles outlined in the Office of Management and Budget (OMB) Uniform Guidance (2 CFR Part 200). The circular explicitly states that expenses “may not be shifted to other sponsored agreements in order to meet deficiencies caused by overruns or other fund considerations, to avoid restrictions imposed by law or by terms of the sponsored agreement, or for other reasons of convenience.” Expenditures should be directly charged to the project account. If overspending occurs, a cost transfer should immediately be processed to move the error to a different account.
Program Income is defined in OMB Uniform Guidance (2 CFR Part 200) as “Gross income earned by the University that is directly generated by a sponsored activity or earned as a result of an award.” Examples include:
UNT may be required to credit program income to the award, and, therefore, GCA should always be consulted for advice if any income is generated by work under a grant.
Certain sponsor-prescribed actions are required to ensure timely reporting of an award. While requirements vary by sponsor, the following reporting is needed for most projects:
If you are the PI on any current or ongoing awards and you are leaving employment at UNT, the following steps should be taken.
If you are transferring to another institution and desire to move grant/contracts(s) to the new institution, you should contact your department head to initiate this discussion. Since the award is issued to UNT, whether a transfer will be allowed is determined by the institution and in conjunction with the sponsoring agency. After the transfer has been approved by the department head, contact GCA to identify the specific transfer requirements for your project’s sponsor. Most frequently on federal awards, a final financial report should be submitted that reflects the unexpended balance that could be moved to your new institution. Please work with the GCA analyst assigned to your award to finalize this balance.
If the grant/contract is to remain at UNT, a new PI must be identified, and the sponsoring agency must approve this person.Typically, this is accomplished with a letter requesting the change and a copy of the new PI’s vitae. A signature from the authorized representative for UNT may be required, depending on the sponsoring agency requirements.
If you are transferring to a new institution, you may want to request transfer of any equipment purchased with grant funding during your employment at UNT. In order to initiate this process, you must prepare a listing to be presented to your department head for approval. Any release of equipment will be at the discretion of the department head and must be approved by the VPRI. A copy of the approved list will need to be supplied to the UNT Fixed Assets Manager so that accurate inventory records can be maintained, and the UNT property control tags get removed. For government owned equipment, the underlying grant/contract document will provide the disposition instructions to follow.
As the PI on a grant/contract it is your responsibility to ensure that the final technical report and any other deliverables as required under the contract documents are delivered to the sponsor within the allowable time frame and prior to your departure from UNT.
Once the PI terminates from their position at UNT any unexpended funds in the PI’s F&A account will revert to the Vice President for Research. If there are ongoing obligations it will be the responsibility of the department to request retention of these funds by supplying an outline of how the funds are to be utilized. The decision to release these funds to the department will be made at the discretion of the VPRI.
Preparing for close-out actually begins upon receipt of an award. The award agreement and prescribed terms and conditions must be reviewed to ensure accuracy throughout the life of the award. Expenditures should be reviewed at least monthly to ensure all charges are appropriate and allowable. Final corrections must be identified and adjusted within 90 days of the award end for most sponsors; however, some sponsors only allow 30 or 60 days.
60 days prior to the end of an award, a notification is sent to the PI by GCA requesting that that all required activities be completed to ensure an efficient and timely close out of the project. At this time, a full review of all direct cost categories (salaries, P-Card, equipment, supplies, tuition, etc.) should be completed in preparation for close-out. Generally, all materials and supplies must be received and services rendered prior to the expiration date of the project. It is the PI’s responsibility to carefully review the related COGNOS report to verify accuracy of all expenses. All accounts payable and payroll encumbrances must be liquidated prior to the award end date. Vendors should be contacted regarding the status of any unpaid invoices.
PI salary/effort should be reviewed to ensure it has been charged according to the sponsor authorized budget. Payroll appointments that continue past the award end date should be transferred to a different funding source. Verify that hourly employees have been fully paid. Cost sharing should also be reviewed to ensure that the fully committed amount will be expended by the aware end date.
Sub-awards are usually concurrent with the award period of the prime award. The PI is responsible for ensuring that the final invoice is received by the date specified in the award agreement. Sub-recipient invoices that are not received, approved and paid by the required deadline are subject to non-payment and de-obligation.
When UNT accepts funds from external sponsors, those organizations presume UNT will expend the funds for the purposes for which they were given and in accordance with any terms and conditions set forth in the award agreement. GCA is responsible for coordination of all audits related to externally sponsored awards. The PI may be called upon to participate in the audit as necessary and appropriate. If the PI is contacted directly regarding an audit, GCA should be notified.
Effort reporting is a method of documenting the work time devoted to an externally sponsored grant or contract and is expressed as a percentage of professional activity devoted to a particular account. All individuals who devote effort to grants or contracts, whether or not they are paid, are subject to effort reporting. Effort reporting is required by Federal regulations Uniform Guidance (2 CFR Part 200) for all compensation/salary costs charged to federal grants and contracts. The regulations require UNT to have a system in place for certifying the allocation of salaries and wages associated with sponsored agreements. UNT employs after-the-fact certification to confirm and substantiate that the activity of an employee supports the compensation charged to federal awards. After each significant term (fall, spring, and summer), a time and effort report is submitted by all employees who perform work on the award. Each person must provide a reasonable estimate of the time actually spent working on the project. PIs are responsible for reviewing all time and effort reports to ensure accurate accountability of their own effort and the effort of their staff in a prompt and timely manner. Certifiers must have suitable means of verification regarding the effort expended on the activities they are certifying.
PIs are responsible for understanding and complying with sponsor requirements for notifications regarding changes in personnel and effort. The PI is responsible for ensuring commitments of effort to awards are met within the flexibility allowed in the sponsor's guidelines and in a timely manner. GCA provides training to PI’s and departmental research staff on UNT’s process for effort reporting as well as on the PI’s role and obligations for effort reporting.
When assessing percentage of activity expended on a sponsored project, total effort is defined as actual effort devoted to all the activities for which UNT compensates an employee for their appointment. For faculty, total effort includes instructional activities, public services and research activities. The federal government guidelines acknowledge that, in an academic setting, teaching, research and public service are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance is placed on reasonable estimates in which a degree of tolerance is appropriate.
However, the percentage of compensation charged to a federal award during a reporting period can never exceed the percentage of total effort associated with the award. If the percentages shown on the report are inaccurate, the PI must initiate a request to the department administrator to process a prior year salary redistribution.
When a faculty member accepts an appointment at another University, and wants to take equipment with them, the request must be approved in writing by the Chair and the UNT Vice President for Finance, the UNT Vice President of Research and Innovation and the other university must be willing to accept responsibility for the equipment and pay for the shipping costs.
Restrictions include:
"Unless specified by the contract or law, it is the intent of the University to erase all software and data files from all data processing storage devices before their official disposition." Licensed software and confidential information may not be transferred.
Assuming all parties agree to the transfer, UNT receives something of value for the transfer, there are no unusual restrictions in the original award document that might limit our ability to transfer title, and the equipment is not being shipped outside the United States, please use the following procedure.
The UNT Property Manager will then review the list of equipment for appropriate value and identify a contact at the receiving University. Property transferred by UNT to an out of state University must occur as a sale for “best value” and the current State sales tax must be assessed (see UNT Policy 10.048).
The UNT Property Manager will collect payment from the receiving university prior to shipment. The receiving University will need to arrange and provide transportation and related costs.