Award management is a critical element of research administration involving a series of processes that must be carefully administered and monitored from the moment an award is received to its closeout.
At our 2023 Connect Virtual Conference, Tolise Dailey (Director of Training and Education Development at Duke University) and David Schultz (Assistant Vice President of Sponsored Research Administration at the University of Houston) shared award management strategies drawn from their collective experience in the field.
This article will summarize the key points from their presentation, which include details on the oversight of sponsored projects and account monitoring.
Award setup
Award setup is the initial phase of award management. This phase involves putting all of the necessary information in place to manage an award effectively.
This information can be divided into four subcategories: grant, subaward, contract/subcontract, and consultant vs. employee.
Grant
Understanding the precise project requirements.
- Scope of Work: Understand the project requirements as outlined in the notice of award, including restrictions and limitations.
- Compliance: Ensuring all compliance areas are addressed, such as conflict of interest (COI) and IRB. Make adjustments and notes in eRA systems as needed.
- Deliverables: Identify specific deliverables the faculty member is responsible for producing under the scope of work.
Subaward
Setting up subawards correctly and ensuring subrecipients understand their responsibilities.
The aim at this stage is to ensure that any changes from subawardees don’t affect the overall scope of work. Considerations for subawards include:
- Budgetary Restrictions
- Terms & Conditions
- Certifications
- Invoicing
Contract/subcontract
Paying attention to the terms and conditions, especially in federal contracts.
The terms and conditions are contracts tend to be very restrictive, as they are a procurement action on behalf of an entity in which they have identified their needs. This stands in contrast to a grant, where you’re identifying the scope of work and what you’re proposing to an entity.
Contracts work oppositely, with an entity specifying their requirements and researchers providing an estimate of the time, effort, and materials required to meet those deliverables.
When setting up contracts and subcontracts, close attention to timelines and milestones is key. Questions to answer include:
- What are you actually getting paid for?
- What is the review and acceptance?
- Are you willing and able to incur the cost of redoing the work if it doesn’t meet expectations from the issuing entity?
Federal contracts involve Federal Acquisition Regulations (FARs) and Department of Defense Federal Acquisition Regulations (DFARs), which lay out the terms and conditions that apply to your specific contract.
Consultant vs employee
Ensuring consultants are not treated as employees to avoid misclassification issues.
Finally, you must ensure that anyone listed on an award as a consultant is truly working outside of the institution, meaning that they have been hired on to manage a project, but they are not functioning in the same way as a full-time employee of the institution.
Consultants should be engaged for a limited timeframe. They should also have their own workspace and dictate their own work. Blurring these lines could lead to challenges about whether the person is truly a consultant or should be deemed an employee, which has associated tax implications.
Administrative requests
In the award stage, we should ensure that we’re doing our due diligence, putting all required information into the system in real-time.
The most common administrative requests at the award stage include:
- Budget revisions/deviations: If we receive requests to change the budget, we must ensure that the change follows the compliance components of the actual notice of award.
- No-cost extension (NCE): No-cost extensions cannot be put forward because you have money left over; federal sponsors, in particular, are very strict about this. When you do your RPPR, you want to ensure that you have finished your scope of work. If not, you should request a no-cost extension and update your federal sponsors before RPPR submission.
- Change in key personnel: If someone leaves mid-award, there will need to be a change in key personnel to bring someone else into the project. If personnel changes, work from prior personnel should stop as soon as you submit the change request.
- Add/remove subrecipients: Adding subrecipients is typically straightforward. If removing a subrecipient, you should be able to explain what changed in the scope of work or why the person was not helpful toward that scope. All subrecipients should understand exactly what they’re supposed to be doing; the institution is ultimately responsible for the actions of their subrecipients.
- Carryover funds: Also tied to the RPPR, carryover funds can extend the lifetime of a project if the scope is consistent but funds are being carried over into an additional timeframe. Research administrators should be able to explain the “why” behind the carryover.
- Foreign travel: If you have foreign travel listed on your award, don’t enter that into a subrecipient award. Research administrators often work closely with travel agencies who understand federal requirements for foreign travel; those agencies are careful to dot their i’s and cross their t’s to ensure compliance. Another consideration is device transport across international borders; be willing to lose any device you’re taking to a foreign country. Back up your files, strip out anything that’s a security concern, and disclose transport to your institution ahead of time.
Account monitoring
Proper governance of direct costs is at the heart of account monitoring, which is all about how an award is being spent. Spending that fits within governance guidelines should be:
- Allowable: Costs that are not prohibited by federal regulations or the specific grant/contract and are easy to prove as belonging to the award.
- Reasonable: Costs that reflect what a prudent person would pay. While prudence is subjective, specific costs should be justified within the proposal. If you can make a case for a cost, you can likely move forward.
- Allocable: Costs are charged to sponsored projects in proportion to the relative benefit received. Allocate costs consistently, being diligent to ensure that changes are tracked and justified.
- Treated Consistently: Like costs in similar circumstances (either direct or indirect) should be treated the same. Treat everything consistently as it’s tied to your institution’s policies and procedures.
Review and subrecipient monitoring
After award setup, research administrators should review the following:
- Actuals to budget
- Salary expenses
- Transaction details
- Investigate and resolve variances
- Error discovery—i.e., cost posted to the wrong project
- Deliverables
- Reporting requirements
Reviewing early sets you up to follow the sponsor’s rules and regulations faithfully and avoid issues that could arise from a violation.
Subrecipient monitoring should also occur, looking at questions like:
- Are they doing the work?
- When do they invoice?
- Do the costs match the agreement?
- If they’re late submitting invoices, why?
Financial compliance
Sponsored research takes a village, and financial compliance is a shared responsibility between the department and central administration.
Reconciliation
Unlike monitoring, reconciliation is the formal process of a deep dive review and documentation. Reconciliation formalizes the monitoring process by certifying monthly transactions and adjusting projections as necessary.
Department:
- Certified review of all transactions
- Adjust projections and encumbrances
- Verify cost share and program income
- Compare committed effort to actual
- Timely initiate cost transfers
Central:
- Ensure no unallowable expense codes
- Monitor burn rates and A/R
- Track cost-share and program income PTD
- Calculate rebudget or effort reduction percentage
- Verify indirect cost and fringe calculations
Closeout
Closeouts are the point at which effort toward an award comes to an end. The closeout process involves:
- Notifications: Sending reminders to the project team at 90, 60, and 30 days before the project end date.
- Reviewing costs: Ensuring all costs are appropriate and encumbrances are liquidated.
- Final reports: Submitting final invoices, financial reports, and other required documentation.
- Updating systems: Reflecting the closeout status in electronic research administration (ERA) and enterprise resource planning (ERP) systems.
Conclusion
Effective award management is essential for the successful execution of research projects. It requires a thorough understanding of the award setup, diligent account monitoring, adherence to financial compliance, and a systematic closeout process.
By following these guidelines, research administrators can ensure that projects are conducted efficiently and in compliance with sponsor requirements.
