Manage Awards

Preparing for an award that includes expertise from outside of your School/College or Syracuse University itself should begin as soon as there is an indication that the proposal will be awarded.  It is at this stage that detailed consideration at the proposal stage will pay off.

Take the opportunity to revisit the collaborator’s statement of work and budget prepared at the proposal stage to be sure it reflects the project needs accurately. It is essential that there are clear expectations regarding the work to be done, that the funds needed for the work are accurate and reasonable and that a determination is made regarding the most appropriate mechanism to define the relationship.

Collaborators can be other employees of Syracuse University outside of your school/college or  they may work with someone from an entity other than Syracuse University.  Processes and considerations differ depending on your chosen collaborator.

When dealing with external collaboration be sure to properly identify the type of collaborator accurately.  They can be Subrecipients or Contractors as defined in CFR 2 Part 200.330 Subrecipient and contractor determinations.

Identifying the type of external collaboration in advance will assist in gathering required documents and in the budget development process.

Subrecipient Characteristics

• Work to be performed will be self-directed with minimal direction from Syracuse University.
• May determine who is eligible to receive federal assistance
• Performance will be measured in relation to whether objectives of the prime sponsor have been met
• Are responsible for programmatic decision making
• Are responsible for adherence to the prime award requirements
• Will use the funds to carry out a program for a public purpose specified in the prime award.

Contractor/Consultant Characteristics

• Syracuse University is buying a service that will support the project. Syracuse will also provide a high level of direction regarding the work being performed.
• Provides the specified goods and services within their normal business operations.
• Provides the specified goods and services to many different purchasers.
• Normally operate in a competitive environment.
• Engaged to provide goods and services that are ancillary to the operations of the prime award.
• Will provide services for the benefit of Syracuse University.

Once the categorization of the collaborator has determined that you are working with a subrecipient, there is a series of processes that must be followed in order to comply with federal regulation and Syracuse University procedures.

Initial Subaward Setup

The PI submits a Request to Issue a Subaward form to OSP.  This document is used to start the process of executing an agreement with a collaborator at another institution.

• It must include:
  • Third-Party Engagement Form
  • Statement of Work
  • Budget/Narrative
  • Appropriate indirect costs
    • Approved rate vs. De minimus rate of 15%
  • Current Contact Information
  • An abstract of the work to be performed by the collaborator.

This request triggers the University’s Subrecipient Monitoring processes.

• Principal Investigators (PIs) have primary responsibility for monitoring a Subrecipient’s technical and financial performance to ensure compliance with both prime sponsor and subrecipient subaward terms/conditions.
• Guidance for the PI can be found in the PI Quick Guide to Subrecipient Monitoring
• OSP conducts Subrecipient Monitoring activities to ensure compliance with federal requirements and SU subrecipient monitoring processes.
  • Process includes the review of:
    • Entity documents are used to evaluate any risks associated with engaging them on a sponsored project.
      • Documents include the Subrecipient Profile, Single Audit, Federally Negotiated Rate Agreements, Financial Statements as applicable
    • Past experience with the entity. Past experience including accuracy and timeliness of invoicing, compliance with deliverable requirements and quality of work are considered when identifying risk.
  • The identified risk will be used to determine specific risk mitigation strategies that can be written into the subaward agreement.
• The PI and the Office of Sponsored Programs understands that failure to adequately monitor the compliance of subrecipients could result in damage to Syracuse University’s reputation and has the potential to jeopardize current and future funding.
• It is the responsibility of the PI and the Office of Sponsored Programs on behalf of Syracuse University, as the pass-through entity, to ensure the good stewardship of sponsored funding.

Subaward Agreement is Issued

• OSP will draft, negotiate and execute the subaward agreement.
• Copies of the agreement will be forwarded to the PI and Department Administrator when finalized.
• Subaward agreements determine the rules for managing your collaborator.

Subaward Modification

As work progresses, there may be a need to make changes to the subaward agreement.  Whenever a change is needed, the PI must submit a Request to Modify Subaward to OSP. The following are things the PI should think about when changes are to be made:

• Do you want to continue collaborating?
• Is the work progressing according to plan?
• Have invoices been submitted in a timely manner and are they appropriate?
• Are compliance issues in order?
• Are reporting requirements sufficient?
• Who is authorized to approve?

Invoices

As work continues the subrecipient will submit invoices for payment. Subaward agreements require that invoices be submitted directly to OSP for contractual review. Once approved by OSP invoices will be forwarded to the PI for approval. The Principal Investigator/Project Director (PI/PD) is responsible for reviewing regularly submitted invoices to ensure that expenditures are reasonable in the context of work performed, progress is being made and to confirm that all required progress reports or deliverables are up-to-date, as required by the statement of work or terms of the subaward.

• The OSP review of subrecipient invoices specifically:
  • Confirms invoice submission is in accordance with requirements of the executed subaward.
  • Confirm invoice includes includes signature & certification statement
  • Confirms invoice details time periods which expenses were incurred
  • Confirms invoice's format includes current period costs, cumulative costs and cost share (if applicable)
  • Confirms expenses have been distributed to major categories (not a one line invoice)
  • Confirms cumulative expenditures do not exceed the total amount of the subaward
  • Confirms expenses are reasonable, allocable, and allowable with respect to the award terms
  • Confirms budget deviations are allowable and within the requirements of the subaward
  • Confirms, if applicable, cost share commitments are met
  • Confirms F&A costs have been calculated correctly
• Prior to requesting PI/PD review, OSP will address any missing/incorrect information or unallowable expenses.  The subrecipient will be contacted directly for additional supporting documentation or any other necessary resolution.  Additionally, invoices that are not compliant with the executed agreement’s guidelines will also be returned for correction.
• While OSP does a preliminary review of subrecipient invoices, it remains the PI/PD’s responsibility to review invoice details to confirm that all the above items are complete and accurate.  In addition, the PI review of subrecipient invoices is contextual and grounded in his/her familiarity with the subrecipient’s statement of work, awarded budget, and reporting requirements.
• All concerns or inconsistencies should be raised directly with the collaborator and/or OSP.  A satisfactory resolution is required prior to approving any questioned invoice.
• Special attention should be given to Subrecipients who do not invoice regularly. Regular invoices provide information to the PI regarding the ongoing work. The lack of timely invoicing is an indication that work is not progressing which may put the success of the entire project in jeopardy.

When the PI communicates approval to OSP, the invoices will be forwarded for payment.

Engaging a Consultant

• PI/Project Staff Responsibilities
  • Select Consultant and document process in accordance with University procurement policies.*
  • Submit the Consulting Agreement with attachments outlining:
    • the service to be provided;
    • the number of days of service involved (per year, if applicable),
    • the daily rate of compensation, and
    • whether travel will be separately itemized.
  • Setup Consultant Commitment and process appropriate invoices
• OSP Responsibilities
  • Review submitted documentation
  • Assure that the Consulting Agreement is complete and fully executed
• Required Documents
  • Employee or non-employee decision process and worksheet
  • Consultant Agreement
    • Consulting Agreement – Companies
    • Consulting Agreement – Individuals
    • Consulting Agreement – Statement of Work Template
  • Third Party Engagement Form

Contractor/Vendor

• Managed by Department Staff
  • OSP does not have a role in this form of collaboration however, OSA will pre-audit expenditures on sponsored projects
• Must follow University Procurement Policies
• Work with the Purchasing Department
• Purchasing Policies can be found at this link: Purchasing Policies

Ensuring compliance with all applicable rules and regulations once a sponsored award is received is an important part of the responsible stewardship of externally sponsored projects.  Federal agency policies and public law provide governance for the regulatory landscape within which University research is performed.

Visit the Responsible (and Ethical) Conduct of Research (RCR/RECR) page to learn more.

During the life of an award, changes take place that requirement action.  OSP is available to assist when changes to the award are needed.

• Budget modification requiring sponsor approval
• No cost extension requiring sponsor approval
• Additionally, prior-approvals are generally required by the award sponsor when there is:
  • A change in the scope of work
  • A change in PI
  • A reduction in effort > 25% or more
  • An absence of key personnel from campus for period of 90 days or more
  • A request for ordinarily unallowable as direct costs
  • Equipment acquisition
  • Extra service requests
  • New Subaward
  • Carry forward request
  • Foreign travel

It is not uncommon for a PI to determine that for efficient performance of the project, he/she must rebudget funds from one budget line or category to another. Many federal agencies have delegated authority to approve these changes or modifications to the University. A matrix of rebudgeting requirements and other prior approvals is available at the National Science Foundation Prior Approval Matrix (PDF).

However, some federal awards and sponsors require that the University (OSP) formally submit a budget modification to the sponsor with an explanation of the need for the budget modification and the anticipated impact, if any, on the conduct of the work. For example, NSF requires ‘prior approval’ to move funds out of participant support category.  Most New York State awards and USED awards require prior approval of budget modifications of a specified dollar amount or percentage of the budget line or award amount, which ever is greater.

Guidance on applicable rebudgeting and prior approval procedures is presented in the “Sponsor Regs” summary document included with the award materials. The PI or his/her designee should first check the sponsor’s award documentation to see if the sponsor has specific guidelines for when a revised budget for rebudgeting is required.

When required, complete the Sponsor Required Budget Revision Form and submit it to the appropriate OSP research administrator (RA) for review. The OSP RA will then work with program staff and other offices as necessary on the revision and submission of budget modification to the sponsor.

To insure that Syracuse University fulfills its reporting obligations on Sponsored Awards, the following notices will be sent out to PI/Department Contacts/Deans.  The effort is intended to:

• Assist those responsible for Technical Reporting in managing their award obligations,
• Eliminate risk of non- payment by sponsors or denial of new awards for lack of compliance with reporting requirements,
• Insure that Syracuse University remains in “good standing” with their sponsors, and
• Assist the Office of Sponsored Programs in maintaining an accurate database of all award activities.

Notifications Regarding Required/Outstanding Technical Reports

At Award – Award Documents (including Project Period and Report Due Dates) are sent to PI and Department Contacts

8-9 weeks before Report Due Date – E-mail Reminder is Sent to PI and Department Contacts

Every Month following Due Date – E-mail Reminders are Sent to PI and Department Contacts for all Overdue Reports

Continued Non –Compliance – May result in delays in new or continuing award set up, loss of the privilege to submit new proposals and/or suspension of sponsored spending

Notifications of Approaching Project End Date

9-10 weeks before Project End Date – E-mail Reminder is Sent to PI and Department Contacts informing them that project is ending soon.  If a No Cost Extension is needed, arrangements must be initiated.

If the Project will be ending as scheduled:

1 week after the Project End Date – E-mail Reminder Sent to PI, Department Contacts and OSA informing them that project is over and no further spending is allowable.

Project Closeout procedures will be initiated.

Reporting Obligations

When submitting applications and accepting awards, Syracuse University agrees to adhere to a sponsor’s reporting requirements. Principal Investigators/Project Directors (PIs/PDs) agree to fulfill these reporting requirements and other sponsor conditions when they sign the Internal Routing and Review form. PIs/PDs and their departmental support personnel are informed of an award’s report deadlines in the Project Brief.

Scientific Progress or Programmatic Reports (Technical Reports)

To insure that Syracuse University fulfills its reporting obligations on sponsored awards, OSP sends notices to the PI/PD and department contact prior to a report’s deadline. PIs are asked to copy OSP (ospoff@syr.edu) on reports transmitted or notify OSP of submission of electronic reports. In the event reports are not submitted in a timely manner, OSP uses an escalating notification process, initially copying the department chair, and finally the dean and the Vice President for Research.

These efforts are intended to:

• Assist those responsible for Technical Reporting in managing their award obligations,
• Minimize the risk of non-payment by sponsors or denial of new awards for lack of compliance with reporting requirements,
• Ensure that Syracuse University remains in “good standing” with their sponsors, and
• Assist OSP in maintaining an accurate database of all award activities.

NOTE: Reports requiring the signature of an authorized official, signing officer, institutional official or similarly named person should be signed by appropriate representatives of OSP.

Financial Reports

Information pertaining to financial aspects of an award are ordinarily provided by the Office of Sponsored Accounting. When appropriate, OSP and OSA will coordinate their efforts to ensure timely submission of reports.

Other reports

OSP also facilitates the submission of other sponsor-required reports in collaboration with other University offices. These include:

• Invention reports – with the Office of Technology Transfer
• Property/equipment reports – with General Accounting
• MBE/WBE – Minority business enterprises  / women’s business enterprises – with Purchasing and Disbursements Offices

Cost sharing required by an award will be indicated on the OSP Project Brief. Ordinarily how cost sharing obligations are to be met was determined at proposal submission and documented through the Internal Routing and Review form.

Because cost sharing is a condition of the award, the PI is responsible for the proper management and oversight of cost sharing expenditures to ensure that this obligation is met. Described below are best practices to meet cost sharing requirements in various situations.

Top Tips:

• Required cost sharing will be noted on you Project Award Brief.
• Do not wait until the end of the award! Upon receipt of your award, discuss plans for incurring cost sharing expenditures with your budget manager.
• Cost sharing should be expended as sponsored funds are expended.
• The PI is responsible for regularly monitoring cost sharing expenditures using the SAMtool or report for PIs includes cost sharing expenditures.
• Most common cost sharing sources:  non-sponsored fund(s) 11, 15, or 16
• Most sponsors require ‘bottom line’ obligation to be met; don’t cost share more than required unless vetted by OSP.
  • Some sponsors require expenditures to follow originally awarded cost sharing budget and follow same rebudget-approval requirements with cost sharing budget as they do sponsored funds. Review the ‘sponsor regs’ prepared by OSP.
  • Some cost-sharing is related to mandatory effort commitments – in these cases – PI (or key personnel) must commit EFFORT, the cost is not the driver, but documenting that the commitment has been met drives the cost.

Simplest scenario Cost sharing is required when noted on Project Award Brief

How:  Add project tail to non-sponsored fund for expenditures such as: personnel effort, materials & supplies, equipment (as allowed by sponsored terms/conditions or solicitation requirements).

NOTE: If it’s not allowable to direct charge, it’s not allowable for cost sharing purposes. Reduced or waived indirect costs may be allowable for some sponsors or solicitations.

Third Party Cost sharing – When a non-SU party is required to contribute to award cost sharing (in subcontract or agreement)

How: Tracking is a manual process – outside of Peoplesoft – handled by OSP

Requires 3rd party certification that cost sharing obligations met; OSP obtains documentation and forwards to OSA so they can certify accuracy of information submitted to sponsor. From time to time, OSP may request additional source documentation to substantiate information certified.

NOTE: If 3rd party does not meet obligation – SU must fulfill outstanding requirement.

When another sponsored project is used as source of cost sharing

How: Cost sharing must be set up and expended in collaboration with OSA; handled in PS.

Work with OSA (current examples:  CASE and COE)