Award Negotiations and Just-in-Time Compliance Reviews
The PI/PD is normally is notified that the proposal has been recommended for funding by phone or email. This notification ordinarily does not constitute an official, legally binding agreement between the sponsor and the University, but rather is a prelude to contract negotiations or grant award. For example, modifications in the application submitted may be required, e.g. reduction in budget and consequent change in scope of work. On occasion, award notices or agreements are sent to other University offices including the Chancellor’s Office or Foundation Relations. In such cases, those units should forward materials to OSP for appropriate action.
Sponsors may also require a documentation of human or animal subjects approvals among other compliance requirements prior to issuing an award.
To facilitate the various steps associated with award review and negotiation and so chartstring creation, the PI is encouraged to:
- Inform OSP that an award is apparently imminent; and
- Forward copies of any materials and documents received to OSP.
In the event of an award, the sponsor may contact either the PI/PD or OSP, or both either by letter or, more often, by telephone. Faculty and staff are reminded that they are not authorized to enter into agreements with sponsors. Letters requesting the PI/PD’s signature for acceptance of the award are to be forwarded to OSP for signature and acceptance or negotiation. Individuals not authorized to sign contracts or agreements may be held personally liable for any untoward consequences of non-compliance.
When the grant or contract is received, it is reviewed by OSP to confirm that it matches the proposal and any agreed upon changes (e.g. budget revisions, statement of work, etc), and that its terms and conditions are in agreement with University policy and principles. Any requirements contained in the agreement but not addressed in the proposal or the original solicitation will be reviewed with the PI/PD to insure that they are acceptable. The agreement may be accepted for the University only through OSP. In no case should any agreement be signed by a staff or faculty member, department chair or dean.
A request to submit a revised budget is often an indication of the sponsor’s intention to issue an award. Revised budgets are to be authorized and submitted by OSP according to the sponsor’s instructions.
If the budget is reduced by 10% or more, ordinarily a revised statement of work should also be submitted to make explicit the impact of the budget reduction on the work plan. Since the budget is the financial expression of the work plan/statement of work, having less funds available means that less work can be accomplished. For some sponsors (e.g. NSF), changes in the statement of work are conveyed via a ‘budget impact statement,’ which should also include a revised budget narrative to justify how funds would be used in support of the project’s objectives.
Other federal agencies, such as NIH or EPA, use a “just-in-time” approach and notify the University of their intent to make an award, contingent upon completion of a cost and compliance review of items such as human/animal subjects approvals or overlap of the new award with existing or pending work.
Award Negotiation Resources and Information
OSP is responsible for ensuring that all compliance requirements, e.g., IRR form, human or animal subjects’ approvals, financial conflict of interest, intellectual property agreement, environmental health and safety etc, have been satisfactorily addressed prior to forwarding materials to Sponsored Accounting for chart-string creation.
The PI/PD is responsible for ensuring that all Syracuse University personnel who will be supported by the project have completed the Intellectual Property Agreement for faculty or staff or students who did not sign the IRR form, and that all project “Investigators” defined as the PI, project director or any other person at the institution who is responsible for the design, conduct, or reporting of a research project, have completed the appropriate disclosure of significant financial interest via MySlice.
Human and Animal Subjects’ Protections
When a proposal to be awarded includes human or animal research subjects, the Office of Research will conduct a comparison of the to-be awarded proposal with the approved IRB or IACUC protocol. The work plan in the to-be awarded proposal must be the same as the approved IRB or IACUC protocol. The PI will be notified of any modifications needed to the protocol to assure that the to-be awarded work is congruent with reviewed and approved protocol.
Projects involving human or animal subjects’ research may not proceed (i.e. chartstring will be restricted or withheld) without appropriate approvals in place.
Environmental Health and Safety
While all submitted applications whose project impacts environmental health and personal wellbeing were preliminarily reviewed by the Environmental Health and Safety Services (EHSS), a more in-depth review is conducted for proposals to be awarded.
Projects that may impact environmental health and safety as indicated by disclosures on the Internal Routing and Review form, or subsequent OSP review will have their chart string restricted or withheld until appropriate approvals are confirmed to be in place by EHSS.
Export Controls
OSP, in collaboration with the PI, will determine if any documentation or licenses may be required for research subject to export controls. Ordinarily basic research is exempt from certain export controls regulations. However, international travel noted on the IRR triggers additional reviews.
Regardless of the funding mechanism, award acceptance for sponsored programs obligates the University to abide by numerous requirements as a condition of award and continued support. In addition to providing progress and financial reports on a defined schedule to the sponsor, among the common award conditions the University agrees to follow when applications or proposals are submitted include:
- compliance with sponsor’s cost policies or cost accounting standards;
- protection of human or animal research subjects;
- disclosure and management of individual or institutional conflicts of interest; and
- compliance with laws, statues or regulations pertaining to civil liberties, lobbying, intellectual property, export controls, anti-terrorism, and recipient eligibility.
Compliance with these and other requirements is a University-wide endeavor and involves the cooperation and assistance of numerous offices including: Research Integrity and Protections, Technology Transfer and Industrial Development, Sponsored Accounting, Purchasing, Disbursements, Human Resources, Payroll, Environmental Health and Safety, Risk Management, and International Student Services. Departmental administration and faculty members also play key roles in facilitating our responsible stewardship of awards.
Forward funding facilitates the start up of a sponsored project and eliminates the need for cost transfers at a later date. For continuing year budget segments, forward funding helps ensure (i) the timely management of payroll or other billings, (ii) the efficient management of departmental resources when preparing the next fiscal year’s budget, and (iii) the less frequent use of salary holding accounts for sponsored activities. The proper use of approved forward funding chartstrings is essential to the achievement of effort reporting compliance.
How to request forward funding.
- Complete the Forward Funding Request form.
- PIs should develop a budget for the amount of funding necessary for the scope of work of the forward funding request. Do not simply submit a request for $99,999.
- Have the form signed by the PI, department/program and unit leadership.
- Submit to OSP for review and processing.
- Requests greater than $99,999 also require the concurrence of the Vice President for Research and written approvals of the Executive Vice President and Chief Financial Officer and the Vice Chancellor and Provost.
When are forward funding requests approved?
OSP reviews requests to ensure that the benefits to the University and sponsor exceed the financial and administrative risks to the University. Forward funding chartstrings ordinarily will be created when:
- all regulatory requirements have been fulfilled, e.g., submission of fully signed Internal Routing and Review form; disclosure of financial interests for all key personnel; human or animal subjects approvals and congruence, as applicable; and environmental protections and personnel safety requirements;
- the likelihood of award is very high; and
- allowable startup or continuation costs need to be incurred to facilitate the efficient conduct or administration of the project.
In the event the anticipated award is not received or costs incurred are subsequently determined to be unallowable by the sponsor or University, forward funded costs will be transferred to the departmental or unit chartstring provided at the time of request.
When will forward funding chartstrings not be established?
Ordinarily OSP will not approve forward funding requests for awards or PIs/key personnel with outstanding/unresolved compliance requirements or for contracts that:
- have uncertain start dates; or
- become effective following execution by both parties.
OSP may also be unable to establish forward funding for federal contracts subject to e-Verify regulations. Contact OSP to explore if forward funding can be used in such instances.
Can forward funding chart strings be used for all project costs?
No. Forward funding may not be used for subaward expenditures on which Syracuse University is prime or higher tier entity unless explicitly authorized in writing by the Vice President for Research prior to expenditures being incurred.
Federal contracts differ from grants in that they are governed by a different set of federal regulations, known as the Federal Acquisition Regulations (FAR). Federal contracts are handled by the government as an acquisition or procurement of service, and are by nature more specific and less flexible than other funding mechanisms such as federal grants. They also require more preparation, supporting material, and are subject to more strict oversight than federal grants. Review of the FAR clauses if available in a sponsor’s RFP, or post award is performed by the Office of Sponsored Programs to determine areas for compliance, as well as, to preserve such principles as the right to publish project results and to maintain ownership of University Intellectual Property.
Direct links to the applicable FAR are listed below.
Contract and Agreement Templates
Syracuse University offers standard contract and agreement templates to support efficient, compliant collaboration with industry and other non-federal partners. These templates balance sponsor interests with the University’s commitment to academic freedom, publication rights, and intellectual property protection.