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As the recipient of sponsored funding, the Principal Investigator has overall responsibility -- fiscal and programmatic -- for the conduct of the project described in the proposal. This means ensuring that all funds spent under the grant are necessary to the research conducted. The Controller's Office and the Office of Sponsored Research are available to help with interpreting guidelines, but it is ultimately the responsibility of the PI to become familiar with and to comply with the regulations of the particular funding agency. The College's grant activity is audited on an annual basis. The failure of PIs to adhere to accepted practices for the management of grant funds jeopardizes the College's eligibility for future awards.
A. From Pre-Award to Post-Award
When notice of funding is received by the College, the Office of Sponsored Research sends a summary of the terms of the grant and full budgetary information to the Assistant Controller, who is responsible for financial administration of sponsored projects. A budget number in the College accounting system is assigned to the award and the PI is notified. Other people notified of a new award include the Manager of the Office of Faculty Records (for grants which include PI salary), the Director of Personnel (for grants which include other salaries) and the Science Center Buyer (for work in the Science Center).
PIs should allow one to two weeks for the assignment of the budget number. Awards which require matching funds from the College will take longer to process, since the source of the match must be identified before a number can be assigned.
Many federal agencies permit grantee organizations to incur pre-award costs up to ninety days before the effective date of the grant. For information about requesting authorization for pre-award spending, consult section V, D, "Changes in the Project," on p.22 of this handbook.
B. PI Responsibility for Project Administration
The Principal Investigator has overall responsibility for the conduct of the project described in the proposal. He or she must monitor the budget to ensure that overexpenditure of grant funds does not occur. This means keeping track of items charged to the project and reconciling the monthly budget statement issued by the Controller's Office in much the same way that people reconcile monthly bank statements for their checking accounts. Except as described below, PIs are expected to spend their project funds according to the categories specified in the approved grant budget and within the time frame defined in the award. PIs are also responsible for ensuring that anyone performing work supported by the grant also understands the relevant guidelines. The other primary PI responsibility is the filing of interim and final project reports as required by the funding agency.
Since sponsor funds are provided to PIs only for the advancement of their research projects, personal expenses should never be charged to a grant, even if it is the intention of the PI to reimburse the grant. Nor should grant funds be borrowed and paid back.
PIs are encouraged to meet with the Assistant Controller and/or Grants Accountant to discuss ways to make oversight of the grant budget easier to accomplish. In general, the Office of Sponsored Research and the Assistant Controller/Grants Accountant can help PIs understand and interpret federal or other regulations concerning allowable expenses.
1. Financial responsibilities of PIs
In general, expenses are charged to a grant in one of five ways: (1) salary charges are authorized by the Office of Faculty Records (for faculty salary) or by the Personnel Office (for other salaries except students); student salaries during the academic year are charged by submission of time cards or transmittal sheets by the PI to the Controller's Office; (2) a check request form is submitted to the Controller's Office, accompanied by documentation that makes it clear that the item or service being reimbursed appears in the grant budget or has been approved through the Organizational Prior Approval System (OPAS) system (described below); in addition to reimbursements, summer student stipends are also normally paid by check request; (3) a purchase order or Science Center requisition is submitted to the appropriate purchasing office; (4) a bill for the purchase of an item or service is submitted to the Controller's Office for payment; or (5) on-campus services (such as Copy Center or Post Office charges) are charged directly by the office that provides the service. PIs should be aware that any salary charges to the grant will automatically trigger fringe benefit and indirect cost charges when the grant budget includes those items.
The items that follow address common concerns of PIs or areas where particular attention to detail is required:
a. Faculty salary - summer salary. Ordinarily, summer salary is limited to 2/9 of the nine-month contract salary. Faculty whose grant budgets include summer salary will receive a memo during May, asking for the amount of summer salary (either a dollar amount or a fraction of academic year salary) to be paid from the grant. PIs may choose to have summer salary paid monthly or in one lump sum during June, July, and/or August. Once the memo is returned, payment of summer salary is authorized by the Manager of Faculty Records. Retroactive requests for payment of summer salary cannot be accepted. PIs who do not receive the summer salary memo and who believe that they may collect summer salary from their grants should contact the Office of Faculty Records.
Federal regulations require that faculty collecting any salary from a federal grant be sure that their effort on the sponsored project corresponds to the salary being paid. Faculty members will be asked to sign a statement that certifies that they expect to expend a month's worth of full-time effort on the project for every month of salary paid. In addition to this prospective certification, faculty must confirm retrospectively that they in fact expended the effort for which they were paid.
b. Faculty salary - released time. PIs whose grant budgets include academic year (released time) salary should inform the Department Chair as soon as an award is made so that the Chair can make the necessary staffing arrangements. If the awarded budget is not sufficient to fully fund the released time originally requested, the PI may have to take a smaller amount of released time. The PI should speak to the Department Chair and the Dean or Associate Dean to discuss how much release is possible. Once all such questions have been resolved, the Manager of Faculty Records will notify the Controller's Office about what portion of the PI's salary should be charged to the grant.
As described above, faculty collecting any salary from a federal grant must be sure that their effort on the sponsored project corresponds to the salary being paid and will be asked to provide confirmation (both prospective and retrospective) to that effect.
c. Faculty salary - sabbatical/early leave. Faculty whose grant budgets include salary in partial or full support of a sabbatical or early leave should inform the Dean/Associate Dean and the Manager of Faculty Records so that the proper arrangements for charging leave salary to the grant can be made. The same confirmation of agreement between salary paid and effort expended on federally-sponsored projects will be required.
d. Postdoctoral fellows. Arrangements for hiring a postdoctoral fellow whose salary is included in the grant budget may be made by contacting the Office of Faculty Records (Ext. 3230).
e. Other personnel. If the project requires hiring new personnel, the PI should prepare a position description as soon as possible and submit it to the Personnel Office (Ext. 2209), which will classify the position and assign a pay grade. Working closely with the Personnel Office will ensure an appropriate classification for the position. Staff working for the project must complete the same certification as faculty relating effort to salary.
Employees working under sponsored research agreements are entitled to the same benefits as other College employees. A performance evaluation should be completed for the employee annually, and salary may be adjusted either on July 1 or on the anniversary date of the grant. All employees who work at least 17 1/2 hours per week, 39 weeks per year, are entitled to vacation after one year of employment. Vacation will be charged to the grant, so it is advisable that employees take vacation during the regular term of the grant. The PI is responsible for maintaining records of vacation and personal days taken.
f. Student salaries. Any student may be hired provided she has a Social Security number. Rates of pay for student employees are established by the Student Employment Office. For students hired on a regular basis, the Controller's Office should be notified; the PI will receive a transmittal sheet on which to record hours worked twice a month. For students who work occasionally, time cards may be obtained from the Controller's Office. Students receiving internships or stipends are normally paid by the submission of a check request form, which may be obtained from the PI's department secretary or from the Controller's Office and which should be submitted to the Controller's Office, Attn: Student Payroll.
PIs should be aware that their grants will be charged for the fringe benefits paid on wages for students working during the summer.
g. Purchasing. The Purchasing Department (Ext. 3026) and the Science Center Buyer (Ext. 3138) assist faculty and staff in the acquisition of goods and services. Any item purchased must be included in the authorized grant budget or must have been approved by the OPAS system. Purchases from grant funds must comply with College regulations. A copy of the College Purchasing Manual is available in each department or from the Purchasing Office.
h. Equipment. Equipment purchased must be necessary to the performance of the project supported by the grant. Since it is difficult to show that equipment acquired within the final months of an award is necessary to the performance of the project, PIs should purchase any necessary equipment early in the grant period. PIs contemplating the purchase of equipment within the last three months of the grant must request approval from the Assistant Controller. The written request should list the equipment to be purchased and state how the equipment is necessary to the research.
Federal regulations require that equipment purchased with federal funds be made available for use on other projects as long as this will not interfere with the work on the project for which the equipment was originally acquired. After the end of the grant period, it is expected that equipment will continue to be used for the original project; if the project is not continuing, the equipment should be made available for other federally-funded projects.
In most instances, title to equipment purchased with federal funds vests in the College; occasionally, title to equipment may vest in the granting agency.
i. Travel. The Controller's Office has issued a separate travel memo (see Appendix II), and, unless further restricted by federal regulations, all travel is subject to general College policy. Original receipts, including airline tickets, must be submitted when requesting reimbursement for travel expenses.
Additional restrictions apply to travel supported by a federal grant. First class travel is not allowed. Foreign travel must be on a U.S.-flag air carrier if "available." Federal regulations state that favorable differences in price or convenience are not considered sufficient justification for travelling on a foreign carrier. No alcoholic beverages of any kind may be charged to a federal grant.
j. Telephones. To arrange for the installation of telephone or telephone lines and jacks, especially for computer equipment, contact Telecommunications at Ext. 3215.
k. Consultants. In general, an individual will be paid as a consultant only if he or she is in a business which normally provides the services being performed. All consulting charges should be carefully documented, including the nature of the services and their relevance to the grant-supported activities, the period of service, the basis for calculating the fee paid, and the amount paid. PIs charging consultant services to a grant need to be aware that NSF sets a maximum allowable rate (available from the Office of Sponsored Research); HHS (which includes NIH) does not have a specific dollar guideline. Payment for consulting services is accomplished by submission of a check request form, which must include the recipient's Social Security number.
l. Subcontracts/subgrants. If the project includes a subcontract or subgrant to another institution, arrangements should be completed as early as possible with the Assistant Controller, who will draft and execute the necessary documents.
2. Reporting responsibilities of PIs
a. Interim Reports. Many agencies require annual (or semi-annual) technical progress reports. The award document identifies the due dates of such reports. The Office of Sponsored Research can answer questions about the format of progress reports.
In some instances, the progress report is required before the agency will award the second or later year of funding. For NSF grants awarded as continuing grants (with specified future fiscal year funding), the progress report must be received by NSF at least three months before the end of the current grant period in order to ensure continuity of funding; NSF does not notify PIs when this report is due. Many multi-year NIH grants have a formal application process for noncompeting continuation, which includes the progress report and budget; NIH does send notice when this application is due.
b. Final Reports. Almost all agencies require final technical reports. The award document identifies the due date of the report, usually 30 to 90 days after the termination date of the project. The Office of Sponsored Research can answer questions about the format of the final report; in some instances, the agency provides a special form. Final progress or technical reports normally include: a summary of the progress made toward the goals stated in the proposal; a description of significant results; a list (and sometimes copies) of publications or theses resulting from work on the project; disclosure of patents or inventions resulting from the project.
Failure to file a final report when due may jeopardize the PI's and the College's eligibility for future funding from the agency.
PIs who believe that their research may lead to material which is eligible for a patent or copyright should discuss the matter with the Vice President for Finance and Administration as early as possible, to work out details of submitting the appropriate application(s).
C. Controller's Office Responsibility for Grant Administration
The Controller's Office has overall responsibility for maintaining financial records for the grant, posting charges as they are incurred, and sending monthly budget reports to the PI. In addition, the Controller's Office requests payment from federal agencies as appropriate, files financial reports, and serves as a link between the PI and the grants management section of the funding agency. The PI can expect to be contacted by the Assistant Controller/Grants Accountant at least three times: (1) when the grant is awarded, a budget number is assigned, and the grant budget is entered into the College accounting system; (2) three months before the end of the grant budget period, as a reminder that the grant is ending, that remaining funds may need to be returned to the agency, and that a no-cost extension may be requested from the College or the agency (see discussion below); and (3) when the grant is closed and the final financial report is filed.
Specific items handled by the Controller's Office include:
1. Fringe benefits and indirect costs.
When the grant budget includes fringe benefits and/or indirect costs, the Grants Accountant charges these items to the grant on a quarterly basis. For most grants, indirect costs are billed as a percentage of salaries and wages; for a few grants, indirect costs are based on modified total direct costs (MTDC).
2. Financial reporting.
The Assistant Controller/Grants Accountant files interim and final financial reports with the agency as required in the grant award.
3. Equipment inventory.
The Assistant Controller/Grants Accountant maintains a record of all equipment purchased with project funds. Every year an inventory is taken to identify the current location, use, and condition of all equipment purchased with federal funds.
4. Institutional audit.
The Assistant Controller/Grants Accountant maintains a continuous record of all financial transactions associated with a project. Under new (1990) federal regulations (OMB Circular A133), the records for all federally funded projects are subject to audit each year by the College's auditors, who must submit a report to the government biannually.
5. Agency audit.
Authorized government personnel have access to all records pertaining to a project. Federal regulations require that all records be kept for three years or until such time as an audit is completed.
Events or problems may require changes in the project. Most of these changes will be minor (a transfer of funds among budget lines, different travel plans, or the purchase of equipment other than that included in the approved budget) and are easily accomplished. Major changes, such as a change in principal investigator or a new objective, may also be made but usually require approval by the funding agency. The Office of Sponsored Research or Assistant Controller/Grants Accountant can provide information about whether an anticipated change is considered minor or major.
1. Pre-award spending.
Many federal agencies permit grantee organizations to incur pre-award costs up to ninety days before the effective date of the grant. PIs who receive verbal notification that an award will be made may request approval of pre-award spending by completing the blue Organizational Prior Approval System (OPAS) form available from the Office of Sponsored Research. The form, which must be signed by the PI, the Department Chair, and the Dean of the College, is then forwarded to the Assistant Controller, along with budgetary information about the expected award. Once pre-award spending is approved, a budget number is assigned and the PI notified as described above. Occasionally, limits may be placed on the amount of spending allowed before the written notice of award is received by the College.
2. Budget changes.
PIs are expected to spend grant money according to the budget approved by the funding agency. Most agencies, however, permit the transfer of funds from one category to another and allow the grantee organization to authorize these minor changes. The rules governing such transfers vary from agency to agency. In general, the College is authorized to approve most changes but is required to maintain documentation which indicates proper oversight of federal money.
To this end, an Organization Prior Approval System (OPAS) is in place for NSF and HHS (NIH) grants. Transferring funds from one category to another requires completing an OPAS form (indicating and justifying the budget change desired), having it signed by the PI's department chair, and submitting it to the Assistant Controller/Grants Accountant, who will approve the request and notify the PI.
PIs should be aware that the budgeting guidelines described in section III, D, "Budget," of this handbook (pp.6-10) apply to rebudgeting as well. In particular, equipment must be necessary to the research and not available or easily accessible. Ordinarily, the purchase of general purpose equipment is not allowed. In addition, increasing or reducing the amount budgeted for salaries and wages will increase or reduce the fringe benefit and indirect cost charges to the grant. If there is a reduction in salaries and wages and associated fringe benefits and overhead, the funds thus freed up may be used for other direct costs of the project.
Adjusting money among budget line items may be done without OPAS approval if (a) there is money budgeted both in the category from which money is to be taken and in the category into which money is to be moved, and (b) the change in either category does not exceed 10% of the original budget for that line.
PIs with grants from an agency other than NSF and HHS should contact either the Office of Sponsored Research or the Assistant Controller/Grants Accountant for information about how to accomplish rebudgeting.
3. Changes in the project period - extension of time.
If the project cannot be completed on schedule, the College may have the authority to grant a no-cost time extension (see below for specific granting agencies). To apply for a no-cost extension, an OPAS form, explaining the need for the extension, should be completed and submitted to the Assistant Controller/Grants Accountant at least 30 days prior to the end of the budget period. This will allow time for the College to approve the request and notify the agency. Note that the fact that funds may remain at the expiration of an award is not in itself sufficient justification for an extension.
In general, requests for extensions longer than the College can authorize (or for extensions beyond expiration dates already extended) must be submitted to the funding agency and should be discussed with the Office of Sponsored Research at least three months prior to the original closing date of the grant for information about how to submit such a request.
No-cost extension rules for specific federal agencies appear below. Grants from other agencies or organizations have rules which are defined in their grant documents.
- NSF: NSF grants are awarded with a 6 month "unfunded flexibility period." The College can extend the project period for an additional 6 months.
- HHS: HHS rules permit the College to grant up to a one-year no-cost extension.
- NASA: For most grants, NASA rules permit the College to grant up to a one-year no-cost extension.
4. Changes in PI or PI's level of effort.
A PI who plans either a short-term or long-term absence from the project or who anticipates devoting substantially more or less effort to the work than outlined in the proposal should contact the Office of Sponsored Research as soon as possible. Such a change would be considered a major change and might result in the naming of a replacement Principal Investigator. In any case, agency notification and/or approval will be required.
5. Institution change.
A PI who is leaving Wellesley for another institution should contact the Assistant Controller/Grants Accountant as soon as possible. In most cases the grant can be transferred to the new institution without problems, but early planning is essential since the process can be quite lengthy.
6. Changes in objectives or scope.
A PI who wants to change the phenomena under study or the objectives of the project as stated in the proposal will have to get approval for such changes from the funding agency. The Office of Sponsored Research can provide information about the mechanism for requesting such major changes. Neither the pursuit of "interesting and important leads" which arise during the course of research nor the adoption of an "alternative approach" which appears to be more promising constitutes a change in objectives or scope, but significant changes in methods or procedures do.