Role of GCA in Post-Award Administration

Role of GCA in Post-Award Administration

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:

  • As new awards are received, establishing an account (Proj ID) in the University financial system.
  • Advising PIs regarding sponsor guidelines and regulations.
  • Facilitating good project management techniques by disseminating information and providing training to PIs on a wide range of topics related to sponsored activities.
  • Serving as the primary interface between the PI and the sponsor in all areas requiring sponsor prior approval, including changes to scope, budget, key personnel, and project end dates.
  • Maintaining project files and records and the PeopleSoft grants information system.
  • Financial reporting to sponsors. GCA prepares the required financial reports that are sent to sponsors.
  • Receivables, billings, and collections. GCA manages the collection of grant funds and maintains account records for each sponsor. GCA draws funds under federal letters of credit as costs are incurred, issues billings to sponsors and follows up withsponsors on payments as required by the terms of agreements.
  • For federal funds, GCA administers the effort reporting function that provides the required documentation for employee salary charges to federal grants.
  • Assists PIs with monitoring for overspending.
  • Coordinates audits.
  • Develops and negotiates federal facilities and administrative agreements.
  • Conducts space use surveys.

Award Notification and Initiation of Account

Award Notification and Initiation of Account

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.

Anticipated Awards

Anticipated Awards

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.

Expenditure/Encumbrance Tracking

Expenditure/Encumbrance Tracking

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.

Equipment Purchases

Equipment Purchases

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).

Personnel Expense

Personnel Expense

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.

Summer Salary

Summer Salary

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.

Travel

Travel

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:

  • The travel is necessary to fulfill the programmatic objective of the project and directly benefits the program being charged, and the cost of the travel is reasonable and allocable to the award.
  • There is a clearly defined relationship between the traveler and their involvement in scope of work being performed.  That relationship should be documented in the travel documentation.
  • Contributed paid or unpaid effort (normally cost sharing) to a project normally provides sufficient documentation of that relationship. 

Foreign Travel

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.

Consultants

Consultants

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.

Expanded Authority

Expanded Authority

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.

Federal Demonstration Partnership (FDP)

Federal Demonstration Partnership (FDP)

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.

Pre-Award Expenditures

Pre-Award Expenditures

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.

No-Cost Extensions

No-Cost Extensions

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.

Budget Revisions

Budget Revisions

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

Sub-awards

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:

  • Review and approve all invoices from the sub-recipient to ensure funds are spent appropriately and within the approved budget.
  • Review and approve budget revision requests from the sub recipient.
  • Monitor the progress of the sub-award and obtain all required deliverables.

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.