POST-AWARD GRANT POLICIES AND PROCEDURES
POST-AWARD GRANT PROCEDURES
Responsibility
Grant awards are made to the institution, not an individual Project Director; therefore, VU assumes full legal responsibility for ensuring that all funds received through the award are used for the purposes and intent outlined in the conditions of the contractual agreement.PROJECT MANAGER
The Project Manager has administrative and reporting responsibilities when managing a grant. It is the Project Manager’s responsibility to be cognizant of all award requirements and contract details, as well as the policies and procedures of VU. It is duty of the Project Manager to review and oversee the successful completion of the contractual and grant funded activities, as well as prevent financial liabilities for the institution. The Project Manager will be responsible for communicating all programmatic, curricular, and budgetary issues to state and/or Federal auditors. The Project Manager has the following specific roles in managing a grant:
Administer the grant budget according to program requirements, initiating and monitoring
grant expenditures, working with Grants and Accounting Office to reconcile discrepancies,
and requesting Accounting to make budget revisions or, if necessary, submitting budget
revision requests to the funding agency for approval.
- Monitor sub-contractors, sub-recipients, and service providers
- Compiling and addressing any requests from external parties involved in monitoring the grant
- Personnel management
- Procurement
- Property management
- Meet regularly with the Grant and Accounting office.
- Manages grant according to all funding agencyregulations and policies.
- Maintains progress reports that provide monthly descriptions of performance indicators including outcome measures as well as budget versus actual expenditures and status of all grant activities.
- Direct the project evaluation, if any, and incorporate evaluation recommendations into the project.
- Track matching funds, if any, including in-kind contributions.
ACCOUNTING OFFICE
Under the general supervision of the University Controller, an accountant performs a wide variety of pre-award and post-award functions including: assisting with budget development, counseling project managers regarding financial status of grant programs and consulting with and providing assistance to administrators and project managers regarding grant financial oversight to ensure compliance with both federal and non-federal guidelines and institutional policies. The specific controls over compliance with grants must be followed by all Project Managers and can be found here.
In addition to ensuring federal grant compliance, the accountant:
- Prepares timely and accurate invoices for submission to grantors and assures that costs incurred on cost reimbursable agreements are invoiced and paid.
- Communicates effectively with and develops professional, effective working relationships with grant administrators such as federal project officers.
- Works closely with University grant administrators, providing guidance on rules and regulations of sponsored programs to ensure compliance.
- Serves as the primary contact at the University for grant administrators on matters of allowability of costs.
- Assists in the implementation of newly issued or revised policies and procedures that affect grant administration.
- Responds to auditor inquiries and provides detailed documentation during audits and reviews of awards.
- Financially manages grants and contracts, including the monitoring and analysis of expenditure levels.
- Manages the grant closeout process, including analyzing and forecasting of data, reporting of data and preparing closeout reports.
- Performs various functions for the month-end close, including creating journal entries, salary adjustments, and reconciliation of accounts.
- Serves as a finance team member by participating in group training and development
activities, contributing grants management expertise to the development of the Grant
Data Warehouse and its reporting.
TIME DISTRIBUTION REPORTS
Many grants allow staff time to be reimbursed through the grant. All salaries and benefit expenses to a grant should be in accordance with the grant agreement. All employees that charge their efforts to grants will be required to complete at least semi-annual time and effort certification reports. See VU Time and Effort Reporting Form – Semiannual for the specific form to use.UNALLOWABLE COSTS
All Project Managers of grants have been provided with the University’s Cost Accounting Policy (see VU Cost Policy Statement). Costs charged to grants that will not be collected from the granting agency for reasons of unallowability, unallocability, or any other reasons must be paid for with University funds.
REPORTING
Technical or narrative reports required by the grantor are to be prepared by the Project Manager, reviewed by either the Program Director or the Grant Office. The Project Manager must maintain all appropriate documentation for the narrative. Project Managers are responsible for obtaining and communicating all due dates for reporting including the final close-out report to the Grant and Accounting Offices.
The Accounting department is responsible for the timely establishment of accounts in the University's financial systems in accordance with the term and conditions of the sponsored agreement. The Director of Accounting is responsible providing the necessary authorizations and Banner training. The Accounting office also identifies and deposit receipts from sponsors to the proper accounts as well as approves all fund transfers and correcting journal entries. Grant programs that will receive money from both Federal and local sources have separate general ledger account numbers and accounts are coded in the restricted account hierarchy.
AUDIT AND RESOLUTION OF AUDITS
Sponsored projects are subject to agency audit, State audit, and University internal and external audit. All personnel responsible for grants should make their best efforts to save all grant documentation, information, and correspondence in a centralized department file. The Department managing the grant should have readily available in this central location the following information: Grant application, grant contract, procurement files, contracts, progress reports, and other documentation necessary by the grant contract and compliance checklist. Some granting agencies perform a closeout audit before the grant is administratively closed by the agency. Notify the Grant Office if and when an audit is scheduled for your grant. The Grant Office will work with each grantee to ensure that all audits are resolved.SUB RECIPIENT MONITORING
The Project Manager is responsible for monitoring any sub recipients of grant funds to ensure the organization is in compliance with the grant agreement. The relationship between a sub recipient and the University is similar to a relationship with any vendor or contractor. Employees that are responsible for hiring organizations to perform services or provide good should always be ensuring that the end product meets expectations. A sub recipient should be held to all of these standards as well. The exception to the sub recipient relationship is that this monitoring must be documented to be in compliance with grant agreements. All sub recipients must sign an agreement with VU. Each Project Manager needs to work with a designated accountant from the accounting office at the beginning of the grant period to determine the process and procedures that need to be developed with monitoring any sub recipients. A monitoring guide will be developed once this meeting has taken place. The monitoring guide will state the specific monitoring schedule to follow.
The Project Manager is responsible for implementing this monitoring and to report the results to the sub recipient in a timely manner. In addition to performing regular monitoring, the Project Manager must review all invoices submitted by the sub recipient to ensure sufficient supporting documentation and that charges are appropriate, in respect to the outlined objectives and budget in the sub recipient agreement.
The designated accountant will be responsible for monitoring the financial performance of all sub recipients. The level of monitoring will be determined by completing an annual risk assessment on each sub recipient to the University. All sub recipients will also be issued an annual letter requesting a copy of the Single Audit report, if applicable.
RECORD RETENTION
Financial records, supporting documents, statistical records, and all other records pertinent to an award shall be retained for a period of five years from the date of submission of the final expenditure report or, for awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report. The only exceptions are the following:
- If any litigation, claim, or audit is started before the expiration of the 5-year period, the records shall be retained until all litigation, claims or audit findings involving the records have been resolved and final action taken.
- Records for real property and equipment acquired with Federal funds shall be retained for 5 years after final disposition.
- Indirect cost rate proposals and cost allocation plans are handled in the following
manner:
- If submitted for negotiation, then the 5-year retention period for its supporting records starts on the date of such submission.
- If not submitted for negotiation, then the 5-year retention period for the proposal, plan, or other computation and its supporting records starts at the end of the fiscal year (or other accounting period) covered by the proposal, plan, or other computation.
documentation of local match
Grants that require local match—a contribution from the University or third party
toward the total cost of the project—must have documentation on file as evidence of
the local contribution. Cash match is a direct outlay of funds for grant activities;
for example, when the University contributes a percentage of the salary and benefits
for grant-funded personnel or supports half the cost of equipment purchases. Inkind
match is the use of existing resources to support a grant project; for example, the
cost of facility usage, postage and duplicating costs, a percentage of existing personnel’s
salary and benefits in proportion to the amount of time spent on the project, unrecovered
indirect costs (i.e. indirect costs not charged to the grant), or third party contributions
of services or assets donated without charge for grant activities.
Match or cost share on federal grants is the portion of project costs not supported
by federal funds (i.e. nonfederal share). Federal regulations are usually more stringent
than those of other funding sources when it comes to what is acceptable as local match.
- Generally, federal funds cannot be used to match funds from another federal grant program. The only time federal funds can match another federal grant is when the authorizing law for each program specifically states that it is allowable. On the other hand, funds from nonfederal grants for expenditures that are directly related to the activities of the federal grant may be used as match for the federal grant.
- Costs for match are allowable only if the costs would be allowable for federal reimbursement. For example, if construction costs are not fundable on a federal grant, then construction expenditures borne by the applicant cannot be used to meet the matching requirement.
- A cost used to match a federal grant cannot be used again to match another federal grant. In other words, matching funds may be counted only once. If the expenditure benefits more than one program, the cost must be prorated so that each program receives a share.
- A cost cannot be claimed as both a grant-reimbursed cost and as a local match expenditure.
- Unrecovered indirect costs (i.e. indirect costs not reimbursed with grant funds) may be used as match only with the prior approval of the funding agency.
- The local match may need to be secured within a certain timeframe, which is usually the grant period; but sometimes a specified period of time before the start date and/or after the ending date may be allowable.
Documentation of local match is the responsibility of the project director.
A Local Match Documentation Report should be completed and signed by the project director and the project director’s supervisor for all University-paid expenses that will be used to fulfill the matching requirements of the grant. The expense may be a purchase of equipment or supplies, travel, consulting services, contracted services, advertising, contracted printing, hospitality, etc. The item should be identified, along with Banner fund for which the expense will be used toward local match. The form should be forwarded to Grants and Accounting. Accoutning will be responsible for distributing and collecting Time and Effort Reports documenting the contribution of faculty and staff time and including this expense in financial reports to the funding agency.
If match involves any in-kind contributions, the project director should work with the Accounting office to determine how to value these contributions.
Program Income
Program income, or revenue derived from federal grant activities, includes income from fees for services performed, from the use or rental of real or personal property acquired with grant funds, and from the sale of commodities or items fabricated under a grant agreement. Please notify the Grants and Accounting Office if any of these items are applicable in your grants.
Record retention
Financial records, supporting documents, statistical records, and all other records pertinent to an award shall be retained for a period of threeyears from the date of submission of the final expenditure report or, for awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report. The only exceptions are the following:
(1) If any litigation, claim, or audit is started before the expiration of the 3-year
period, the records shall be retained until all litigation, claims or audit findings
involving the records have been resolved and final action taken.
(2) Records for real property and equipment acquired with Federal funds shall be retained
for 3 years after final disposition.
(3) Indirect cost rate proposals and cost allocation plans are handled in the following
manner:
- If submitted for negotiation, then the 3-year retention period for its supporting records starts on the date of such submission.
- If not submitted for negotiation, then the 3-year retention period for the proposal, plan, or other computation and its supporting records starts at the end of the fiscal year (or other accounting period) covered by the proposal, plan, or other computation.
GRANT CLOSE OUT
All closeout reports required by the granting agency will be reviewed by the designated accountant before submission to the agency. The Project Manager is responsible for reviewing the grant fund at the end of the grant period to determine if there are unspent or overspent funds. The Project Manager will report this information to the designated accountant no later than 90 days after the close of the grant period. Any unspent funds that are requested to be carried forward must have documentation from the granting agency that approves the carry forward.
University Accounting/Procurement Policies/Forms Link can be found on VU-x.
Contact Information for Post Award Activity:
Angie Worland, Director of Accounting
aworland@vinu.edu
(812) 888-4308