SIUC SPONSORED PROJECT GUIDE

   Section 7: Account Set-up and Grant Management

• 7.1   ORDA Responsibilities
• 7.2   Grant & Contract Accounting Responsibilities
• 7.3   Principal Investigator (PI) Eligibility and Responsibilities
• 7.4   Fiscal Officer Appointment and Responsibilities
• 7.5   Establishing an Account
• 7.5.1  Advance Accounts
• 7.6   Account Budget Lines and AIS Information
• 7.7   Rebudgeting (Budget Reallocation)
• 7.8   Program Adjustments and Time (No-Cost) Extensions
• 7.9   Subawards
• 7.10  Project Reports
• 7.11  Invention Disclosures
• 7.12  A-21 Cost Categories and Effort Distribution Reporting
• 7.13  Property Control and Transfer of Equipment
• 7.14  Grant Records - Management and Retention
• 7.15  Scientific Records - Management and Retention of Data
• 7.16  Audits
• 7.17  Closeout of Grant
• 7.18  Transfer of Grant to or from SIUC

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7.1  ORDA Responsibilities

When you receive notification of a pending grant or contract, contact the ORDA project specialist assigned to your college. Our office reviews, negotiates (if necessary), and processes sponsored project awards (see section 6 of this guide). When an award has been fully executed—meaning that the final award agreement has been signed by ORDA and by the funding agency—ORDA sends the award documents and a copy of the Proposal/Award Checklist to the Grant & Contract Accounting section of Accounting Services so that an account can be set up for the project. See Establishing an Account, below.

ORDA's contract specialist works with principal investigators to issue any necessary subcontracts or subgrants required by a project.

ORDA staff also handle any budget reallocations, program adjustments, and time extensions that require agency notification, serving as facilitator and liaison between the granting agency and the principal investigator. Contact the ORDA project specialist assigned to your college with such issues or with any other questions you have about the overall administration of your sponsored project.

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7.2  Grant & Contract Accounting Responsibilities

Grant & Contract Accounting, a unit of Accounting Services, sets up grant/contract accounts and administers the financial aspects of externally funded grants and contracts. An accountant is assigned to each grant or contract and is the fiscal officer's contact regarding the financial aspects of the grant. The accountant assists the fiscal officer by interpreting University and funding agency policies and procedures concerning fiscal practices and allowable expenditures. He or she helps to resolve any problems with the financial management of the grant or with the accounting reports generated in relation to the project.

Grant & Contract Accounting pre-audits many proposed commitments by the fiscal officer, such as purchase requisitions and invoice distribution forms, before they are processed by the Purchasing Office or the Accounts Payable Office. If there are problems, such as commitments in excess of available funds, transactions are not processed but are referred back to the fiscal officer.

Grant & Contract Accounting handles certain budget reallocations and time extensions that do not require agency notification. It also prepares cash requests (billings) to funding agencies, prepares closeout documents when the grant ends, and prepares and files required financial reports.

Questions about the fiscal management of a grant or contract should be directed to the accountant assigned to the project (536-2351).

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7.3  Principal Investigator (PI) Eligibility and Responsibilities

2. A/P research staff (researchers/scientists): Those holding the title "Senior Scientist" may serve as principal investigator. "Assistant Scientists" and "Associate Scientists" may not serve as PI unless their relevant department chair or center director and dean make exceptions for them. "Researchers" may not serve as PIs.

3. A/P nonresearch staff: These staff may serve as PI if their supervisor approves. The primary criterion is the individual's capability to lead and administratively manage the project. In some cases, a department may decide that the staff member may direct the project but may not serve as the fiscal officer.

4. Postdoctoral fellows, graduate students, and undergraduate students may not serve as PI.

PI Responsibilities

In administering a project, the PI is representing the University and is responsible for upholding the high standards expected of SIUC projects ("best-effort" performance). The overall scientific and administrative integrity of the project, including design and conduct, validity of results, and preparation of manuscripts, rests with the PI. His/her responsibilities include:

• planning expenditures properly (whether or not he/she serves as fiscal officer);

• training and supervising staff on the project;

• complying with the terms and conditions of the award;

• completing work in a timely fashion;

• fulfilling the objectives and scope of work of the grant;

• ensuring the project complies with University, state and federal government, and funding agency policies and regulations, including but not limited to those relating to human subjects, animal welfare, hazardous materials and biosafety, occupational health and safety, conflicts of interest, civil rights, affirmative action, intellectual property, research misconduct, drug-free workplace, use of University property, electronic information privacy, and equipment purchases;

• maintaining and archiving data, including research records necessary to support patent activity (see section 7.15);

• ensuring quality control of all data and materials generated by the project;

• determining authorship:

• submitting reports to the funding agency as required in the award agreement; and

• observing any other legal stipulations in the award agreement, such as provisions concerning treatment of proprietary information and disclosure of patentable discoveries made in the course of the project.

If rebudgeting, program adjustments, time extensions, or changes in key project personnel become necessary on your grant, contact the ORDA project specialist assigned to your college as soon as possible.

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7.4  Fiscal Officer Appointment and Responsibilities

In most cases, provided that the principal investigator is a full-time employee of SIUC on continuing appointment, he or she will serve as fiscal officer of the grant or contract. Some colleges and departments, however, are more restrictive about who may be a fiscal officer. The chair and college dean approve the appointment of the fiscal officer by their signature on the Proposal/Award Checklist.

• The fiscal officer is responsible for all grant transactions and signs off on all fiscal and personnel paperwork. See sections 7.5 and 7.6 below.

• The fiscal officer must monitor the funds available in the grant account and ensure that the account is not overexpended. If the fiscal officer overexpends the account or expends funds for unauthorized purposes, he or she must appeal to the department chair or dean to cover the expenditure.

• The fiscal officer also is responsible for the property (inventoriable equipment) charged to the account. See section 7.13 below, Property Control and Transfer of Equipment.

If account expenditures must continue while the fiscal officer is away from campus for an extended time, he or she can submit a Temporary Delegation of Fiscal Officer Authority.

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7.5  Establishing an Account

Grant and contract accounts are administered via the University's AIS (Administrative Information Systems) financial system. Grant & Contract Accounting assigns each grant an AIS budget purpose number (account number) and a related "fund number." The budget purpose number is used on hiring and fiscal forms and to look up information about account balances and expenditures on the central AIS web site. The fund number is also used to access certain information on this site. (For more information about AIS and monitoring grant accounts, see section 7.6 below.)

Once these numbers are assigned, the fiscal officer is free to hire staff and make expenditures in accordance with the terms and conditions of the award agreement. Hiring and purchasing procedures are summarized in this guide, section 8, Hiring Staff, and section 9, Other Account Expenditures. Another grant management resource is the Grant Accounts section of the Accounting Services web site.

For the time being, grants are also still being issued an FAS account number (FAS being the University's old accounting system). This is because the P-card transactions are still coded by FAS number. If you manage more than one grant and have to assign P-card expenditures to the proper grant when reconciling your statement, you will need to refer to these old FAS grant numbers. Eventually the P-card system will also be converted to AIS, and the old FAS numbers will no longer be used.

Remember that a grant account cannot be issued unless the project has received any necessary approvals for work involving human subjects, human stem cells, vertebrate animals, hazardous biological, chemical, or radiological substances, or recombinant DNA. See section 5.1, #3.

7.5.1  Advance Accounts

To obtain a budget purpose number before the award is fully executed, the principal investigator must have verification in writing from the funding agency of the award amount and project start date. By memo or e-mail, the PI's dean/director (or designate) must authorize the advance account. (E-mail must come directly from the dean or designate's e-mail address.) The e-mail or memo must specify the account that would be used to cover any advance expenditures should the award not come through, as well as any advance expenditures later found to be unallowable under the award agreement. If your college does not agree to this provision, the account cannot be established in advance.

Note: For some types of contracts the State of Illinois is no longer allowing accounts to be set up for projects until the funding agency signs the final grant documents. Advance accounts are not possible in these cases.

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7.6  Account Budget Lines and AIS Information

For information about hiring procedures, see Section 8, Hiring Staff. For information about procedures for paying travel expenses or buying equipment, commodities, and services, see Section 9, Other Account Expenditures.

Information about budget expenditures and account balances can be accessed via the AIS web site at any time, using the grant's budget purpose number and/or fund number of your grant. If you don't already have a user name and password to access grant information on AIS, fill out a Request for New User Access to AIS form and submit it to Accounting Services, mail code 6812.

Fiscal officers of grants have access to two monthly online reports, "Funds Available Report" and "Report of Transactions," to help them track grant expenditures and account balances. E-mail alerts are sent when these reports are available on the AIS web site.

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7.7  Rebudgeting (Budget Reallocation)

If rebudgeting requires agency approval, or if you need to exceed the percentage of rebudgeting that the award agreement allows you, contact the ORDA project specialist assigned to your college. Give him/her the details about what funds you need to transfer between budget lines. ORDA staff will get approval for the transfer from Grant & Contract Accounting and then from the funding agency.

If you have questions about rebudgeting or other expenditure items, contact ORDA.

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7.8  Program Adjustments and Time (No-Cost) Extensions

No-cost extensions: A time, or no-cost, extension is a program adjustment that involves no change in the scope of work and no additional funding. The only change is a delay in the end date of the project. If the funding agency must approve or be notified of a no-cost extension, the extension is handled through ORDA. Call the ORDA project specialist assigned to your college for assistance. For fixed-fee accounts, which do not require agency notification, ORDA handles the first requested extension to assure that deliverables have been met. After that, any desired annual extensions are handled by Grant & Contract Accounting.

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7.9  Subawards

Subcontracts or subgrants are issued by the University for collaborative grant/contract activities involving personnel at other institutions. When a subagreement (subcontract, subgrant, or memorandum of understanding) is required, the principal investigator should contact Sonjie Schwartz at ORDA, 453-4541, as soon as possible. The scope of work and budget for the subagreement are normally provided by the PI. If needed, ORDA will assist the PI in developing the scope of work and budget.

The use of subagreements ensures that all applicable grant or contract clauses are included to meet legal, financial, and reporting requirements. Subagreement documents are prepared by ORDA with the assistance of the principal investigator. The ORDA director signs all subagreement documents on behalf of the University. ORDA will work with the subawardee's institution to implement the subagreement.

If you have been awarded a subcontract or have made subawards to other institutions from your prime award, you should read the suggestions below for subcontract management. You should also familiarize yourself with Subaward (Subrecipient) Monitoring Guidelines in section 10 of this guide.

Facilitating Work with Subcontractors

With advances in research and instruction comes the expectation that complex initiatives and project proposals will sometimes be required to solve researchable problems or meet scholarly needs. The challenge for the PI and, ultimately, the PI as a "project manager" when the proposal is funded, is to put together an effective solution or approach.

One strategy is to seek the collaboration of other researchers or scholars through subcontracts (or subgrants when grants rather than contracts are involved). These subcontractors can be used to accomplish work that may not be within the PI's expert area, to relieve the PI of some project tasks so he/she can work on other tasks, and to provide technical assistance using equipment, instruments, assessments, or analyses not available to the PI.

Most subcontract arrangements work well and add to the success of the project. Without careful project management by the PI, however, subcontract problems can outweigh the benefits. Keeping the following guidelines in mind can help.

Note:Throughout these guidelines, the terms "subcontract" and "subcontractor" can be used interchangeably with "subgrant" and "subgrantor." Subgrants are similar to subcontracts. Due to the nature of grant-funded research and scholarly projects, the obligation of the subgrantee to adhere to the scope of work is slightly less since grants are inherently more flexible. However, the elements of the subgrant are essentially the same as those of the subcontract. Questions regarding this distinction should be referred to ORDA.

Terms

The project manager, usually the PI of the grant or contract, takes responsibility for oversight of the project throughout its duration. The project manager ensures that objectives are met within the specified time, that the costs incurred fit the budget, and that the quality of the project reflects well on the PI and the University and is acceptable to the funding agency.

Subcontractors are individuals, usually outside of the University, who perform a specific part of the project or provide a specific service needed for the project. Subcontractors are usually identified through the PI's personal contacts, past research or scholarly collaborations, and recommendations by others.

Subcontracts are formal agreements between the PI's institution and the subcontractor. The subcontract, at a minimum, must include a scope of work for the project, a description of the services or tasks to be performed by the subcontractor, and a schedule for deliverables, including any reports. The subcontract document must be executed by the University and the institution employing the subcontractor (or, if an independent subcontractor is used, by the subcontractor). Although monthly or quarterly progress payments or cost reimbursements are made at intervals over the time period of the contract, final payment for services normally occurs after it has been confirmed that the work performed by the subcontractor is satisfactory and in accordance with the terms of the subcontract agreement.

Successful Project Management

The relationship between the PI/project manager and the subcontractor is key to the success of the subcontract. The PI must work with ORDA to ensure that the subcontract includes a scope of work that clearly communicates what is expected of the subcontractor. To the greatest extent possible, the scope of work must be detailed, with time lines for accomplishing tasks and producing reports of results, and with methods, procedures, and analyses clearly specified.

The subcontract is a binding agreement between the parties involved. As such, the subcontractor must produce the work specified in the subcontract, and cannot be required to produce work that is not specified. It is in the best interest of the project and of the subcontract relationship that there be a clear specification of exactly what will be done under the subcontract. In addition, federal regulations govern subcontract monitoring.

However, it is important to remember that research and scholarly activities tend to evolve as projects progress. Overly restrictive subcontracts may not allow for changes in the scope of work that may be necessitated by new findings or unexpected developments during the project. A balance between a focus on subcontract requirements and a collaboration with the subcontractor throughout the project is also important.

When There Are Problems

Problems or concerns can arise on the parts of the project manager and the subcontractor during the course of the project. These problems may involve differences of opinion as to the quality or quantity of the work performed, the cost of the work, the timeliness of reports or results, and the methods used in performing the work. It is not always possible to avoid problems, but the information contained above under "Successful Project Management" is a good starting point.

Other steps that might be used include the following:

1.  Discuss the project with the potential subcontractor before submitting a proposal or working toward developing a subcontract relationship. One of the aims of such a discussion should be to determine if the potential subcontractor can perform the work needed within the time frame required. It is also important to know the subcontractor's strengths and weaknesses, possibly from other researchers or scholars who have worked with the subcontractor, to determine reliability, work quality, and cooperativeness.

2.  If problems come up during the course of the project, talk with the subcontractor about what is needed and what is lacking in light of what was agreed to in the subcontract. Try to work out a suitable accommodation. If possible, keep on top of the work being performed so that any performance problems on the part of the subcontractor are identified early, not so late in the project that there is too little time for remediation. If the PI/project manager also has responsibilities that affect the subcontractor's work, such as providing materials needed by the subcontractor, it is important that those responsibilities be taken seriously and met in a timely fashion.

3.  If the problems involve work that is needed but not specified clearly in the subcontract, it may be difficult to get that additional work performed without a mutually-agreed-to subcontract modification or by voluntary compliance from the subcontractor. This is why it's critical to know the subcontractor's strengths and weaknesses before a subcontract is considered and to develop a good working relationship with the subcontractor.

4.  If the problems are not resolved by talking with the subcontractor, discuss the problems with Sonjie Schwartz (453-4541). This is especially important since the problems may involve aspects of the subcontract language that might be needed to enforce performance requirements by the subcontractor. Sonjie also can be helpful in discussing the matter with the subcontractor's institution, business, or agency.

5.  If the problems are not resolved, it may be necessary for the PI/project manager, ORDA, and others (e.g., Grant & Contract Accounting, University Legal Counsel) to work together with the subcontractor's institution, business, or agency to determine what can be done to resolve the situation. This collaborative approach has been found to be more useful than the PI working alone.

Typically, the subcontract must be relied upon as the basis for determining issues such as the quantity of work, adherence to the scope of work, and costs. Issues of work quality are more difficult to determine and may be more contentious, thereby requiring more time to resolve. However, every attempt will be made to resolve the situation if possible.

Sometimes situations cannot be resolved to everyone's satisfaction. In these cases, University Legal Counsel must provide guidance about the costs/benefits of different possible courses of action, and the University must consider issues such as legal liability, relations with the funding agency that may affect other faculty, previous or ongoing relationships with the subcontracting institution, business, or agency, and the fiscal magnitude of the issues involved.

A Final Note

Dealing with collaborators on research and scholarly projects is becoming more commonplace and expected, both by universities and by funding agencies. Because more people are involved, there are more opportunities for differences of opinion, differences in work style, and other personnel issues to arise. The guidelines above are intended to suggest ways in which smooth working relationships might be fostered between PIs as project managers and other researchers and scholars as subcontractors. ORDA staff can help significantly with the planning and administration of subcontracts.

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7.10  Project Reports

Some funding agencies now require electronic submission of progress and final reports. Contact the ORDA project specialist assigned to your college if you have any questions about an agency's electronic reporting requirements. Allow extra lead time if you are new to that particular agency's electronic system.

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7.11  Invention Disclosures

Invention disclosures to the University should be made in writing to the Intellectual Property Committee through ORDA. [Invention Disclosure Form] The next higher University authority, usually the department chair, must be informed in writing at the time the disclosure is submitted. See SIUC's Intellectual Property Policy for details.

Note that proper laboratory recordkeeping is crucial to legally defensible patent claims and protection in the case of a dispute over an invention. See section 7.15.

Licensing agreements may be made with businesses in order to transfer technology (products or processes) from the University research laboratory to the marketplace. The University and the agency sponsoring a research project can negotiate licensing options as part of a grant or contract. See the Technology Transfer web site for information.

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7.12  A-21 Cost Categories and Effort Distribution Reporting

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7.13  Property Control and Transfer of Equipment

The fiscal officer of the grant or contract is responsible for any property, such as inventoriable equipment, charged to the grant/contract account. A current inventory list may be obtained at any time by contacting the Fixed Asset Accounting section of Accounting Services (536-2351). See Equipment Transactions on the Accounting Services web site for helpful information about property control and equipment inventorying.

The University must have written approval from Central Management Services (CMS), a department of the State of Illinois, before any grant-purchased equipment may be removed from SIUC. Contact Fixed Asset Accounting to obtain a Request to Permanently Transfer Sponsored Project Equipment with Researcher form. The equipment may not be transferred until written approval is received from CMS. Transfer of equipment without this approval is a violation of state regulations.

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7.14  Grant Records - Management and Retention

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7.15  Scientific Records - Management and Retention of Data

• Scientific Recordkeeping (Fox Chase Cancer Center)

• Record-Keeping Procedures (Harvard University)

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7.16  Audits

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7.17  Closeout of Grant

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7.18  Transfer of Grant to or from SIUC

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Questions/comments about the Sponsored Project Guide? Contact Marilyn Davis
Office of Research Development and Administration
Southern Illinois University Carbondale

last updated 09/05/07

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