Post-Award

Setting up a cost center (project) for your award in financials system

Carol Kessel in accounting will set up a project number that is specific to your award when official notice is received. The account number she provides should be used for charging all expenditures on the award. You will receive access to view activity on this project using Peoplesoft Report Manager.

Overhead award:

Trinity’s policy is to return 20% of the indirect costs to the faculty member to be used for grant related expenditures that are not covered by your award. A separate account will be set up for your expenditures (also provided by Carol Kessel).

Award Budget:

Expenditures must adhere to federal guidelines for allowable costs (NSF, NIH) as well as Trinity’s spending policies. Please submit grant expenditures to your department’s administrator. If you have any questions about allowable costs, contact the Grants Office or the Controller.

Purchasing Guidelines:

Purchases on your grant will be handled through your administrative business office. Equipment with acquisition value of $5,000 and over is recorded in the college’s fixed asset system. This equipment cannot be removed from use, sold or transferred to another institution without permission from the Dean of Faculty and VP Finance. Periodic inventories of equipment purchased using federal funds are conducted by the Controller (Purchasing Policy and Procurement Policy).

Important note regarding purchasing for federal grants: For projects funded by any agency of the U.S. Government, goods and services may not be purchased from any entity that is excluded from receiving federal funds through contracts, subcontracts, and certain other forms of financial assistance. Before committing to any purchases under federal grants, the PI/PD must consult the Excluded Parties List System to ascertain that the prospective vendor has not been debarred.

Travel:

Fly America Act:  the FLY America Act requires any that government-funded travel be undertaken on air carriers flying under the U.S. flag. For further questions and assistance accessing the list, please contact the director of faculty grants.

Hiring of Research Personnel:

Please contact Mary-Susan Snyder ([email protected]) in Trinity’s HR department to initiate the hiring process of personnel for grant-funded positions. The hiring process can take several weeks to complete and should be initiated well in advance of your intended project start date. Federal funds cannot be used towards student work-study matches. Payments to independent contractors (professional service providers and other individuals who are not college employees) must be made directly by Trinity College. Specific information is required for reporting and tax purposes. Non-cash payments to individuals (participants and others) must be preapproved and documented to satisfy federal agency and IRS requirements.

Responsible Conduct of Research (RCR):

PIs and anyone conducting research (undergraduate students, graduate students, postdoctoral fellows, paid or unpaid) are required by federal agencies (NSF, NIH) to complete RCR training. PIs are responsible for ensuring the completion of training for all individuals before their start date and agree to provide completion certificates to the Grants Office. 

Trinity College has a policy for the review of alleged unethical research practices. To view this policy and a list of infractions, please see Appendix 6 of the Faculty Manual.

Internal Review Board (IRB):

Approval and training is required for research with human subjects. The Institutional Review Board (IRB) reviews and evaluates faculty and student research that involves the collection of information from human participants.  

Institutional Animal Care and Use (IACUC):

Approval and training is required for research with animal subjects. The Institutional Animal Care and Use Committee (IACUC) oversees the institution’s animal program, facilities, and procedures.  

Federal Conflict of Interest (FCOI):

PIs must update each year of the project. 

Off-site research:

NSF’s PAPPG (Proposal & Award Policies & Procedures Guide) requires proposers with off-campus or off-site work, to certify that they have a plan in place for creating and maintaining a Safe and Inclusive Working Environments for Off-Campus and Off-Site Research for that project.

The NSF defines “off-campus or off-site research” as follows:

“Off-campus or off-site research” is defined as data/information/samples being collected off-campus or off-site, such as fieldwork, and research activities on vessels and aircraft. Each proposing organization must determine whether the proposed work is considered off-campus or off-site. This does not include off-campus or off-site research being done for education or outreach.

Before grant seekers planning to do off-site work submit applications to the NSF, they must complete Trinity’s Plan for Safe & Inclusive Off-Site Research.

Time and Effort reporting:

The federal government requires certification of time and effort to verify that federal funds were charged only for time worked on allowable cost activities of a grant project. 

Adjustments may be granted to project scope or budget with prior approval from the funding agency. Discuss any anticipated changes with the Grants Office and Associate Comptroller as soon as possible. This may include: 

• No-cost extensions; 
• Significant changes in methods, procedures or budget; 
• Significant changes, delays or events of unusual interest; 
• Conflicts of interests that cannot be satisfactorily managed, reduced or eliminated; and 
• Changes to PI/PDs level of effort or changes to employment at Trinity. 

Intellectual Property Policies:

For more information, please refer to Appendix 9 of the Faculty Manual. 

The College complies with all federal regulations and has the following assurances filed with DHHS: civil rights, misconduct in science, handicapped individuals, sex discrimination, age discrimination, drug-free workplace.

Public Access to Results:

Federal grants require that researchers provide immediate public access to research papers and data upon publication. Verify the specific of public access policy of the funding agency (NSF, NIH) 

Reports:

Federal grants require regular reports on a schedule mandated by the agency (NSF, NIH). Please note that failure to submit timely reports can result in federal agencies blocking all funding to the institution. 

Cost Transfers Policy

PIs are required to submit transfer requests to and from sponsored research and other academic departments to the Director of Academic Finance for approval. Supporting documentation and/or written justification is required. The approved transfers are forwarded to Accounting Services for processing. The transfers are reviewed for verification of the vendor, expense amount, need to request missing support, general ledger review to ensure that a voucher has not already been transferred, etc. The Accounting Manager prepares a journal entry, which is reviewed and approved by Controller and AVP Finance. The time frame for identifying and correcting errors varies based on period of performance, external reporting and other factors specifics to the research project and nature of the transfer. PIs and other personnel are informed that the deadline for processing cost transfers is 90 – 120 days after the date when the original expense was posted.

Cost Allowability Policy

The budget categories funded in the award provide a general guideline for allowable expenses to the PIs. The review of all expenses prior to processing payments by the Director of Academic Finance addresses proper allocation, allowability and reasonableness of costs.

A cost is considered reasonable if it does not exceed the amount or type of expense that would be incurred by a prudent purchaser under the circumstances prevailing at the time the purchase was made.

A cost is allocable to a federal award if the goods/services involved are assignable to that award in accordance with relative benefits received. Appropriate allocation methodologies include effort, space, head count, FTEs in project, number of experiments conducted, and percent of time in lab space. Splitting costs based on available funds in each project or evenly to projects without additional consideration are prohibited. Documentation supporting the methodology used must be retained.

The Uniform Administration Requirements describe costs that are not eligible costs. The Cost Principles in 2 CFR Part 200 of the Uniform Guidance contain a full list of the types of costs. Unallowable costs should not be charged to a federally sponsored project, unless the award specifically dictates allowability. Unallowable costs include cost overruns, entertainment, marketing, advertising/public relations and student activity costs, alumni activities, memberships in community organizations and social clubs, first class travel, honoraria, alcohol purchases, lobbying costs, charitable contributions, fine and penalties, subscriptions and office supplies, bad debts and interest expense.

Discussion with the Controller may occur if the review raises questions about a specific cost.

Written standards and internal list

The college’s Budget Director provides to department heads, directors and program managers a listing of expenses that are considered unallowable for all purposes.  The Faculty Grants site provides additional guidelines for costs related to sponsored research.

Unallowable direct and indirect costs

Indirect costs are recorded by the Controller, based on the budget allocations for the performance periods, and the related expenses. The identification of unallowable direct costs would occur during prepayment review by the Director of Academic Finance or by post payment review by the Controller. The unallowable expense would not be tracked within the project using an alternate account code. The cost would be transferred by the Controller to an unrestricted fund or an appropriate project, based on discussion with Director of Academic Finance, department head or other manager.

Exclusion from indirect cost rate calculation 

Unallowable costs are identified and completely removed from the project. There are no conditionally unallowable costs in the specific award project to be excluded from the indirect cost rate calculation.

Record Retention Policy

All college Accounts Payable vouchers (including original requests and all support documents) are scanned into the college’s online image system and are permanently accessible. Support for Payroll transactions such as additional compensation requests are also scanned into the document retention system. Timesheets and approvals are maintained in the Peoplesoft payroll system.

The record retention period begins at the end of the performance period of the award. The Controller maintains individual award files, audit reports and financial reports for seven years after the award end date. Financial services has a specific retention schedule for specific documents and other support.

Budget Revision Policy

Budget revision requests initiation, approval, processes

PIs contact the Director of Faculty Grants to discuss budget revisions. Following preliminary review of the proposed revision, the PI is asked to present the request in writing, normally via email. The request is circulated to the same individuals who review and approve the original proposals in the Dean of Faculty, Faculty Grants and Accounting Services areas.

Budget revisions that require prior sponsoring agency approval

The Dean of Faculty and the AVP Finance approvals must be received prior to submission of a budget revision request to the NSF Program Officer by the Director of Faculty Grants. The process outlined is followed for these submissions, and the approvals are requested before the request is made to the sponsoring agency.

Budget updates in accounting system after revision request is approved

The Controller informs accounting assistant of budget revisions and reviews updated project report to ensure revision is reflected correctly.

Budget revision request denial

A budget revision request may be denied where reallocation would result in a substantive change in the scope of a grant. If internal approvals may also be declined due to departmental conflicts or constraints.

Approved budget revision

Chart of accounts is submitted separately. Template for review and approval of budget revisions is submitted separately.

Budget and Expenditure Monitoring Policies

Internal controls in place to preclude incurring obligations in excess of total funds

The Director of Academic Finance receives and approves all invoices, reimbursement requests, etc., and  forwards to Accounting Services for payment. Accounts Payable passes all payments requests to Accounting Manager for review against project funds available prior to processing.

Secondary review

Detailed expenditure reports are updated after month end close and distributed to PI. Director of Academic Finance has access to Peoplesoft trial balance, which is updated daily. PIs have access to the Peoplesoft trial balance reports for their sponsored research projects. The Controller reviews restricted fund trial balance as part of month end close process.

Cost overruns identified and resolved

PIs generally contact the Director of Faculty Grants, the Director of Academic Finance or the Controller to discuss potential expenditures which could result in cost overruns. Other cost overruns are identified during the prepayment review process. All issues are resolved by identification of alternate funds available to the PI to cover the additional expense.