Managing a sponsored project award is a collaborative effort between the investigators, departmental staff, and OSP.
Program Director (PD)/Principal Investigator (PI)
PD/PIs are responsible for completing the scope of the project within the project budget, for preparing and submitting any required technical reporting due to the sponsor, for completing Project Verification Statements (PVS), and for ensuring costs charged to the award are in line with university and sponsor rules and regulations. PD/PIs are also responsible for working with subaward investigators and communicating with their department financial staff any changes or concerns. See Managing Subawards
Departmental Staff
Departmental staff is responsible for processing financial transactions and working with the PD/PI to ensure that expenditures are in line with university and sponsor rules and regulations.
OSP - Grants Accounting
Grants Accounting is responsible for setting up the project and budget in SAP, monitoring the project, providing guidance on sponsor rules and regulations, reviewing sub-award invoices, requesting reimbursement from the sponsor, filing required financial reports with the sponsor, and audits.
See Sponsored Project Fiscal Responsibility for additional details.
Setting up an Award in SAP
OSP Grants Accounting maintains the official accounting records pertaining to all externally funded sponsored projects, regardless of funding source. This is accomplished through the establishment of appropriate university WBS elements in which all sponsored project expenditures and reimbursement transactions are recorded.
To ensure all university and sponsor requirements and reporting are met, all externally funded sponsored projects received by UNO will be accounted for as Restricted Current Funds, which require that a separate WBS element be established for each sponsored project to document and account for the receipt and expenditure of such funds.
An award will be set up in SAP when all of the required information has been received. In SAP, the award will be captured within a WBS. This WBS number is 13 digits long and begins with a ‘4.’ Information needed to set up this WBS number includes:
- Award Document – Signed by all parties
- Detailed budget that matches sponsor award amount and institutional cost share
- Signed, completed routing form – including signatures for cost share (if applicable)
- Verification of applicable compliance (human subjects, vertebrate animals, ionizing radiation, hazardous materials, and recombinant DNA approvals)
- Current Conflict of Interest Disclosure
- Subaward Information (contact information, budget, detailed statement of work), if applicable.
- Subaward WBSs will be initiated and created once the subaward agreement has been executed.
- Copy of proposal
Upon award execution, OSP - Awards will send out a notification to the PI and all applicable stakeholders on the NuRamp form. Upon notification, OSP Grants Accounting will review the form/documents and begin their review and setup.
Set-ups are processed within 7-10 business days as long as all information needed (see above) is complete. WBS numbers are not set up for the Responsible Person (PI) if they have delinquent PVS’s outstanding.
Project Expenditures
All charges to the award must comply with university and sponsor rules. Charges posted to an award must be for goods or services directly benefiting the award and rendered during the award period.
Charges to federal or federal pass-thru awards must meet the criteria of 2CFR§200. Generally speaking, costs must be reasonable, allocable, allowable, and treated consistently.
- 2CFR§200 defines reasonable as the actions a prudent person would have taken under similar circumstances to purchase the item for this cost. For a charge to be reasonable, it must be necessary for the performance of this award. If the charge is due to special circumstances, it should be documented in the file.
- Allocable means that the award directly benefits in the proportion of the expense that was charged to it. The cost must be incurred solely to advance the work under the sponsored agreement, or it must benefit the agreement and other work of the university in proportions that can be approximated through the use of a reasonable method. Or it is necessary to the overall operation of the university, and it is deemed to be assignable in part to a sponsored project.
- Allowable means that this expenditure is permitted as a direct cost under the terms and conditions of this specific award or contract. Treated consistently means that like expenses are treated the same in similar circumstances. (I.e. office supplies would generally be considered indirect costs and not directly charged to an award unless there are documented, extenuating circumstances.)
Charges must be allocated to an award in direct proportion to the benefit received by expense. This allocation must be documented and a reasonable method used. Charges for items not in the approved budget may require prior written sponsor approval. A copy of this approval should be kept in the department’s financial files and sent to OSP Grants Accounting. If written sponsor approval is not required, the charge should be documented with the justification for its need.
Pre-award Spending
Some sponsors allow for sponsored project charges to be incurred up to 90 days prior to the start of the award. If sufficient notification has been received from a sponsor to determine that an award will be made, the award may be set up in SAP if the PI provides OSP Grants Accounting with the following:
- Written documentation from the granting agency stating that UNO will be receiving the grant award, the award amount, and the award period
- If UNO is to be a subreceipent, a copy of the prime's award notice
- NuRamp form number; must be fully routed and approved
- Internal budget and budget justification (uploaded to NuRamp)
- Written documentation from the chair/dean/director stating they will cover the expenses incurred in the event the award is not received by UNo and a cost center to use in this event
Once the items listed above are provided to OSP Grants Accounting, the assigned grants accounting will review the request and ensure pre-award spending is allowed by the sponsors and to check for any additional sponsor requirements. Upon review, the grants accountant will request final approval from the Grants Accounting manager. If approved, a Pending WBS will be created.
If an award is subsequently not made, any expenses charged to the award must be removed and covered by the department.
Salary Distribution and Certification
The largest category of direct project expense at UNO is salary and benefits. The PI is responsible for reviewing salaries charged to projects, and for validating and certifying percentages of salary charged to a project.
When a PI manages a team with multiple ongoing projects, the distribution of salaries of the PI, research assistants, researchers, graduate assistants, and other staff to the various projects must be carefully considered. UNO's process for salary distribution and certification verifies that direct labor charges to federally sponsored agreements are reasonable, and reflect actual work performed.
This is commonly referred to as effort reporting using Project Verification Statements (PVS). This process shows the distribution of the effort of individuals among the various activities in which they work, as a percentage of total salary (not as a specified number of hours) devoted to benefit the project, either as a direct charge or committed cost sharing.
Charges for work performed on sponsored agreements during all or any portion of such period are allowable at the institutional base salary rate (IBS). IBS is defined as the annual compensation paid by the university for an individual’s appointment, whether that individual’s time is spent in research, instruction, administration, or other activities. IBS excludes any income that an individual earns outside duties performed for the university.
In no event will charges to sponsored agreements, exceed the proportionate share of the IBS for that period. This principle applies to all members of the faculty at an institution. Some sponsors may choose to cap the salary or salary rate at a maximum level. In these cases, any salary over that cap is an unallowable expense on that project.