Post-Award

The award is made to the University, not an individual. Notification of a sponsored program award to the University may be simply an award letter, a purchase order, a detailed contract, or an agreement spelling out the terms and conditions of the award. Generally, the notification of award goes to Sponsored Programs Office.

If award notices (or letters of decline) are sent directly from the funding agency to the Principal Investigator or other University officials, original copies should be forwarded to RAS at ora@howard.edu .

Awards that fail to follow internal processing compliance, review, and approval through RAS may be refused by the University. In all cases, the University is not obligated to accept an award.

Award Set Up

Before spending begins on an award, there are certain steps that must occur to set up awards for spending or to allow pre-award spending. The required steps include receipt of an award document from the sponsor, review, and approval of the award on behalf of the University and setting up the award in the University's financial system.

Award Management

During the post-award phase in the life cycle of an award, award management requires that all relevant central departments and the related school/college ensure the administration of the sponsored program award is conducted in compliance with pertinent university, school, and sponsor policies and procedures. Sound fiscal and programmatic management of sponsored programs is critical.

Advance/Pre-Award Spending

Principal Investigators (PIs) may request authorization to spend funds in support of a sponsored program in advance of receiving a notice of an award from a sponsor when allowable by the sponsor. The awarding agency is under no obligation to reimburse such costs if for any reason the University does not receive an award or if the award is delayed or is less than anticipated and inadequate to cover such costs.

Sponsored Programs vs Gift

The University's approval, negotiation, agreement and management processes with regard to accounting, budget practices, oversight, and compliance practices differ depending on whether funds received are categorized as a gift. Therefore, it is essential that the categorization of external funding received must is determined by utilizing an understanding of the various considerations that dictate the determination of the funding type.

Subcontract/Independent Contractor Agreement Negotiations

A subaward is provided through a subcontract (also known as a subaward). It is an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of the program. An independent contractor (also known as a consultant agreement) is issued to a person or entity contracted to perform work for/or provide services to the University. An independent contractor is not a University employee. Subcontracts and Independent Contractor agreements are negotiated and executed by RAS. Work should not begin until a fully executed agreement is in place.

Subrecipient Monitoring

In accordance with OMB Uniform Guidance as a Pass‐through entity, Howard University must monitor the subrecipient to ensure that the subaward is used for authorized purposes, is in compliance with Federal statutes and regulations, and achieves performance goals.

Participant Support

Participant support costs are direct costs for items such as stipends or subsistence allowances, travel allowances and registration fees paid to or on behalf of participants or trainees in connection with conferences or training projects. Sponsor approval must be obtained before incurring participant support costs on sponsored program awards

Budget Revisions

Many sponsors permit variances within budget categories without prior approval. Budget revisions may be necessary if the planned expenditures differ from the original or approved sponsor budget. Since policies differ from sponsor to sponsor, it is important that the PI work with RAS to understand Budget Revision policy of the sponsor prior to revising the budget.

Cost Transfers

At times record-keeping errors will occur, however they should be identified and corrected promptly. Therefore, it is essential that PI's review their accounting information regularly (i.e. monthly but no less frequently than quarterly) to identify transaction posting errors. Federal regulations require written or documented justification for any expense transfer or reassignment to or from sponsored programs.

No-Cost Extensions

Many sponsors will allow No-Cost Extensions for sponsored programs. A no-cost extension is a request to extend the project period end date without requesting extra funding. The PI should work with RAS to understand the No-Cost Extensions policies, procedures and requirements of the sponsor.

Changes in Key Personnel

If there is any change in key personnel on a project, typically a grant amendment/sponsor approval is required. Written prior approval must be secured from the sponsor through RAS if key personnel will be absent for more than 25 percent (for most sponsors) of the project implementation period or more than three months. The PI should work with RAS to understand the Change in Key Personel policies, procedures and requirements of the sponsor.

Carryovers

Carryover is when unobligated funds remaining at the end of a budget period are approved to be carried forward to cover allowable costs in the next budget period. The carryover of funds enables recipients to use unexpended prior year grant funds in another budget period. The PI should work with RAS to understand the Carryover policies, procedures and requirements of the sponsor.

Project Reporting

As a recipient of an award, regular reports documenting a project throughout its lifespan may be required. These reports may include both expense-related data and quantitative information about the project's impact. The PI should review the terms and conditions of the award and work with RAS to understand the reporting requirements of the sponsor.

Award Closeout

Closeout of an award is the process determining that the Statement of Work has been completed and that all applicable administrative and financial actions required for an award have been completed. The PI should work with RAS to understand the Award Closeout requirements of the sponsor.

Record Retention

When requirements for retention of records overlap, the responsible office should retain records for the maximum period needed to meet legal and audit requirements. Legal and audit requirements generally dictate how long financial and project records should be retained.