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Overview of Post-Award Administration at Smith

Post-award consists of processes that occur between award inception and award close-out. During this period, Grants Accounting, and the Principal Investigator  and staff, must continually monitor the award fund to ensure the project is running smoothly, and to ensure compliance with internal and sponsor external policies and procedures, federal regulations, and grant specific terms and conditions.

Some of the most often utilized post-award activities include:

In addition to these activities there are some requirements that are specifically related to special awards such as Federal Contracts and American Recovery and Investment Act Funding that the college has established procedures to ensure compliance.

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Award Receipt, Negotiation, and Approval
When the College receives an award notice the process moces from a pre-award to a post-award stage. Grants Accounting works closesly with the Sponsored Research Office (SRO) to ensure the smooth transition from pre-award to post-award activites, and with Principal Investigators and staff in the post-award administration of those awards.

Grants Accounting will work with the Principal Investigator to receive and/or negotiate the grant or contract.  The process begins with a review all of the terms and conditions of an award, where Grants Accounting will highlight any special terms and conditions, such as restrictions, and requirements, as well as verify the elements of the agreement.

If necessary, Grants Accounting will negotiate on behalf of the college and the Principal Investigator on the terms and conditions of an award.  If there are no concerns or a negotiation process, the award will move to a setup process.

All awards flow into the Grants Accountant and are officially approved by the Director of Budgets and Grants or other designated institution official. 

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Award Setup and File Maintenance

After the receipt of an award, the Grants Accountant will setup a new grant and fund number in the Banner system.  Award specific information is entered so that it can be appropriately tracked.  An electronic file is established on the shared to electronically store grant information and activities over the life of the grant.  There is also a paper file setup to do same.  Both the electronic and paper files are maintained by the Grants Accountant.

After the award is setup, Grants Accounting will send an official email notification to the Principal Investigator and relevant administrative staff with the relevant project information, including the grant number, project dates, reporting requirements, Banner Access information, and restrictions, if any.  It will also include information about budget setup. 

The budget plan is the financial expression of the project or program as approved during the award process.   Once a grant has been awarded, the approved budget is entered into Banner. The awarded budget may be different then the proposal.    Grants Accounting will always enter the budget as is awarded by the sponsor.

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Monitoring Budgets

The PI/PD is responsible for monitoring all expenses charged to the grant.  Grants Accounting recommends that you review your grant budget at least once a month in Banner in order to avoid cost overruns and identify any misallocations.  Mistakes can happen, but expenses posted to a grant in error can be moved easily if the error is caught within a short period.  Be sure that all invoices, vouchers, and payroll charges that have been submitted are charged to the grant properly. Grant budget overruns are charged to the PI/PD’s department.

You can review your grant budget by logging into Banner.  There are three ways to access Banner data: Banner INB, Banner Web or ePrint.

BannerINB provides Real-Time information and can be accessed using your Web browser.
BannerWeb is also Real-Time Information, though the amount of information available is more limited than Banner INB.  It can be accessed from the Smith College Home Page.

Eprint is static information as of the report date.  This information is usually a month in arrears.  It will also provide you with detailed activity on your grants, such as payroll information, that is not available to you via Banner INB or Banner Web.  E print may be accessed from the Faculty/Staff page of the Smith College web site. 

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Expenditure Review and Approval
All non-compensation expenses allocated to any sponsored project are reviewed and approved by Grants Accounting before processing to confirm that the expense is consistent with the terms and conditions of the award and to identify that sufficient documentation and justification is provided. One exception to this procedure is ProCard Expenses, which are reviewed by Grants Accounting after they have been posted (see ProCard Expenses). An expense is allowable on a sponsored project if it meets the following criteria:

  • Reasonable—a prudent person would have purchased this same item and paid same price; an arms-length arrangement.

  • Allocable—expense is allocated to a project in proportion to the benefits derived to the program objectives; the investigator is the responsible person who determines the proportional charge to the project.

  • Consistently Treated—like expenses are treated the same by the institution given same circumstances.

  • Allowable—all three above criteria met and the expense is permitted as a direct cost per the terms and conditions of the award.

Expenditures on Federal agreements are subject to the provisions of OMB Circular A-21 "Cost Principles of Educational Institutions".  If you have questions regarding the allowability of an item, you are encouraged to contact Grants Accounting (2218) prior to placing the purchase.  Click A-21 Restrictions to read a notice regarding expenditures on Federal awards.

Documentation is required to be maintained for purchases made from sponsored funding sources. Required documentation for federally funded purchases can include purchase orders, invoices, copies of competitive quotes or proposals, justification for sole source selection, and cost/price analysis, as well as approvals.  The rule of thumb is that all documentation should be “Self-Explanatory”.  All expense documentation is scanned into the Banner system and retained pursuant to federal and state laws as required on grants and contracts.

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ProCard Expenses

ProCard expenses may be directly charged to a grant.  However, consistent with the college’s ProCard policies and procedures (http://www.smith.edu/purchasing/pcard.php) it is the responsibility of the card holder to approve and submit the backup documentation to his or her supervisor for review and approval.

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Journals and Cost Transfers
Grants Accounting assists with budgeting and reviews costs that are charged to sponsored projects at Smith College.  This process ensures a fair degree of reasonable allocation and allowability of costs to sponsored projects.  However, occasionally errors in posting and allocation occur in any accounting system.  It is the responsibility of the Principal Investigator to periodically review and ensure the reasonable allocation and accuracy of costs charged to the sponsored project.  A periodic review should occur within a reasonable period of posting to the ledger.  Principal Investigators should review their federal awards on a monthly basis.  Once a transaction has posted to the Smith General ledger and it needs to be reallocated, the request for transfer is either a journal or a cost transfer.
All  journals and cost transfers, payroll and non-payroll, must be authorized by the Principal Investigator or designee and be reviewed and approved by Grants Accounting prior to being processed. 
Journal requests should include the journal, a screenshot or printout of the original posting of the transaction, copies of all original documentation, along with a reason for the reallocation.
If the item is identified as a cost transfer then it must include all of the above documentation required for a journal as well as a completed Cost Transfer From. 

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Cost Transfer Policy
Proper management of funds is essential to uphold the fiduciary responsibilities of the college.  It is the policy of the college that costs be charged to the appropriate sponsored project when first incurred. However, there may be circumstances in which it is necessary to transfer expenditures to a sponsored project subsequent to the initial recording of the charge.

Such transactions require monitoring for compliance with Smith policy, Federal regulations, sponsor specific guidelines, and the cost principles that guide fiscal activities on sponsored projects.

This cost transfer policy is intended to meet these requirements.

Definition


A cost transfer is more commonly known as a journal entry which specifically reallocates an expense to a federally sponsored fund after the expense was initially charged to another fund.  Cost transfers can include reallocations of salary, wages, and other direct costs.  These transactions will require completion of a cost transfer form along with a journal entry, and relevant documentation, and must be approved prior to processing.

The College determines the following instances to be standard journal transactions and not cost transfers.  (i.e. Cost Transfer Form and Approval is not needed).  These transactions should be processed in accordance with the college’s standard journal transfer guidelines in the normal course of business.

  • Transfers made within the accounting period (month) of the original charge.
  • Transfers of original expenses less than $500.
  • Transfers to correct improperly classified account code
  • Transfers to correct transactions to invalid code combinations involving only the org and/or program code

Allowability and Timeliness


To be permissible, cost transfers must meet the criteria established for both timeliness and appropriateness. 

Costs Transfers less than 90 Days
Cost transfers must be timely.  They should occur as soon as possible after the original transaction and be processed within 90 calendar days after the 15th of the month following the accounting period of the date of the original transaction.  A cost transfer can only be made under appropriate circumstances when the expense qualifies as an allowable direct cost of the sponsored project being charged.
Typically, cost transfers are appropriate when their purpose is to:

  • Correct errors in processing the original charges;
  • Move costs between funds for closely related work (as defined by the project scope) that is supported by more than one funding source;
  • Transfer pre-award expenses in accordance with the provisions of OMB Circular A-110, Section c.25.
  • Retroactively adjust salary costs between projects to reflect an individual's actual effort on the projects.

Inappropriate circumstances include, but are not limited to, the following:

  • Transfers solely for the purpose of utilizing an unexpended balance;
  • Transfers for the purpose of avoiding a cost overrun by charging another, unrelated sponsored project;
  • Transfers that circumvent pre - and/or post-award restrictions.

Costs Transfers exceeding 90 Days
Approval for cost transfers submitted later than 90 calendar days (as defined above) will only be granted in extenuating circumstances.
Transfers that would result in the revision of a final Financial Status Report (FSR) or Final Invoice will generally not be approved.

Procedure


All cost transfers, payroll and non-payroll, must be authorized by the Principal Investigator or designee and be reviewed and approved by Grants Accounting prior to being processed. 
The Requestor must complete a Cost Transfer Form (which explains why the transaction is taking place) and answer the appropriate questions.
If the cost transfer is 90 days or less (as defined above), answer questions 1 and 2 and obtain appropriate approvals.  If the cost transfer is great than 90 days, all 4 questions must be answered and appropriate approvals must be obtained.  See form for approvals.
Proper documentation of the specific costs being transferred must accompany the cost transfer request. This includes the date of the original charge, copies of invoices and/or accounts payable vouchers, and a journal voucher.  The grants accounting office must be able to ensure that actual, identifiable expenditures are being transferred, not lump sum amounts. 
For further information, contact Grants Accounting at (413) 585-2200.

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Internal or External Approvals and Project Changes or Extensions

The budget plan is the financial expression of the project or program as approved during the award process. Once a grant has been awarded, the approved budget is entered into Banner. The awarded budget may be different then the proposal. Grants Accounting will always enter the budget as is awarded by the sponsor.

After a grant has been awarded, the PI may determine that the approved budget allocations are not consistent with actual project needs. S/he may request a reallocation of funds from one spending category, or account code, to another account code category that better reflects the project requirements. This process is called rebudgeting or budget revision.

There are other changes to a grant that involve either internal or external approval.  These can include:

  • adjusting the length of a project period,
  • changes in scope of work,
  • significant changes in methods or procedures,
  • addition of a subaward
  • change of PI or addition of a Co-PI
  • pre-award costs in excess of 90 days
  • rebudgeting of budget line items
  • rebudgeting of participant support costs

The type of request along with sponsor requirements and grant terms and conditions, designates whether the request can reviewed and approved internally or externally with the sponsor.  It is important to note that in either case, the request must be reviewed and approved.

Many federal agencies have transferred the authority to approve such changes to awardee institutions. Smith’s implementation of these authorities is described in the Organization Prior Approval System (OPAS).

If the Principal Investigator wishes to modify the awarded budget or make another administrative change to their grant, they should contact Grants Accounting for the proper procedure to do so.  The Grants Accountant will advise if the PI should follow the OPAS procedure or seek prior approval with the sponsor.

The actual request for change must be made in writing either using the OPAS form or via email, or memo, whichever is relayed as the appropriate mechanism.

See OPAS Form

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Effort Reporting

The federal government, through the Office of Management and Budget (OMB) Circular A-21, Section J.10, requires effort certification on federally-sponsored activity.  In order to receive and maintain eligibility for funding, sponsoring agencies require accurate and reasonable documentation to support that labor costs charged to sponsored accounting units are consistent with the effort expended.  This certification is reviewed for the following two purposes:

  • To verify that the percentage of effort placed on a federal award is not less than the percentage of salary charged to the accounting unit.
  • To capture any voluntary cost sharing by indicating an excess percentage of effort as compared to the percentage of salary.

This Effort Certification Policy is intended to meet this federal requirement.

  • After-the-Fact Reporting

Smith College uses an “After-the-Fact Activity” system to comply with the federal effort certification requirement. Under an after-the-fact system, distribution of salaries and wages for employees working on externally-funded projects will be supported by activity reports. Charges are made initially on the basis of estimates made before the services are performed. Activity reports will reflect an after-the-fact reporting of the actual percentage distribution of activity of employees. If significant (>10%) differences between the charges and actual distribution, the charges will be promptly adjusted to reflect actual activity.

  • Employee Effort Certification Reports

Employee Effort Certification Reports will reasonably reflect the percentage distribution of efforts expended by Smith College faculty and exempt professional staff involved in federally-funded grants, contracts, and cooperative agreements. The report will account for 100% of an employee’s actual effort for the given time period.

100% effort is defined as the effort expended to accomplish the full set of activities encompassed by Smith College appointments regardless of the actual number of hours expended on those activities. 100% effort is not defined as a single, standard number of hours or days per week because it will likely be different for each faculty/staff member and may vary during the year. The number of hours implicit in an individual faculty member's 100% must be reasonable and supportable to department, school, college and external reviewers if requested.

The employee should indicate the percent effort (number of hours worked on an individual activity divided by the total number of hours worked for Smith College) for all federally-sponsored research and curricular (i.e., instruction, administration, public service) activities.

The employee should provide an account of all effort expended on a sponsored activity, even if the sponsor did not compensate the employee for that activity, which constitutes “cost sharing.” This can occur on a mandatory or voluntary basis. Mandatory cost sharing occurs when it is required by the sponsor at the time of application.  Voluntary cost sharing represents additional effort expended on a project that is not required by the sponsor.  Although it is the College’s practice to minimize voluntary cost sharing, the PI must record all effort expended on their projects regardless the source of compensation.

Employee Effort Certification reports do not need to be completed by clerical staff or students that fill out a weekly time sheet.

Principal Investigators will be required to verify that the information provided by any employees working on their grants is accurate.

Employee Effort Certification Reports are required for three reporting periods annually. Effort certification report requests will be distributed to all applicable employees approximately 15 days from the close of a reporting period. Completed reports must be submitted to the Controller’s Office (College Hall 204) no later than the 30 days after the distribution of the effort certification report request. The reporting periods and approximate submittal deadlines are provided as follows:

    1. Summer (June 1–August 30); submittal deadline – October 15
    2. Fall (September 1 – December 31); submittal deadline – February 15
    3. Spring (January 1 – May 31); submittal deadline – July 15

Completed Employee Effort Certification Reports will be filed in the Controller’s Office.

Other Items of Note

  • When a PI is absent in excess of 90 days from his/her project, approval must be obtained from the sponsoring agency.
  • Changes in effort require approval from the Provost/Dean’s Office and/or the Sponsoring Agency as appropriate.
  • Time spent in the preparation of proposals cannot be charged to a sponsored accounting unit.  Therefore, it is inappropriate for an employee to be paid from sponsored accounting units to prepare and submit proposals.

For further information, contact Grants Accounting at (413) 585-2200.

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Reporting

Grants Accounting prepares all financial reports required by the sponsoring agency. Do not provide any financial information to a sponsor without verification by the Grants Accountant.
The PI/PD is responsible for all narrative or technical reports. Many sponsoring agencies require annual progress reports; check the specific grant terms and conditions. Copies of all narrative reports and correspondence related to faculty-initiated grants should be forwarded to Grants Accounting.  Copies of all narrative reports and correspondence related to institutional grants should be forwarded to the Office of Corporate & Foundation Relations.

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Sub-Recipient Payments & Monitoring

Sub-recipients submit invoices directly to Grants Accounting. After initial review Grants Accounting forwards the invoice to the Principal Investigator for approval. Once the PI has approved it, the invoice is returned to Grants Accounting to verify signature and is processed as any other grant expense.

Before the invoice is approved by the PI it should be reviewed to insure that charges are correct and allowable for the billing period in question. If the PI does not agree with any charges the invoice should not be approved and the sub-recipient should be notified of any issues. Invoices should only be approved if the work is satisfactory to the PI.

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Grant Close-Out

A grant is considered closed once all of the requirements for final reporting and all deliverables have been fulfilled and accepted by the sponsor, and all income has been received.

At the end of a sponsored project the fund will be reviewed for any errors. During this process if any unallowable expenses are discovered the charges must be transferred to a departmental fund. Cost Sharing and Effort Reports will be verified and deficits need to be cleared. Additionally, any open encumbrances must be closed. If the project is fixed price and a balance exists, Grants Accounting will close-out the fund according to the Close-Out of Fixed Price Agreements instructions.

After all internal and external requirements have been met, the Grants Accountant:

  • Prints the final financial data from Banner \
  • The fund and the grant numbers are closed.
  • The paper file is marked closed and stored with closed files
  • The electronic file is reviewed to ensure all electronic retention of all documents, in conjunction with required per the college’s Documentation Retention Policy... 

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E-Verification

E-Verify is an Internet based system operated by the Department of Homeland Security (DHS) in partnership with the Social Security Administration (SSA) that allows participating employers to electronically verify the employment eligibility of their newly hired employees. 
Any federal contract or subcontract, awarded after September 8, 2009, that includes the E-Verify clause (48.CFR pts 2, 22, & 52), and that exceeds 120 days and $100,000, and subcontracts that include the clause and exceed $3,000, are required to E-Verify all new hires. 

All employees working on a Federal Contract for Smith College must complete a Form I-9 and the Office of Human Resources must enter this information in the E-Verify system.

America Competes Act

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America Competes (ARRA) Reporting


When are ARRA reports due?
Section 1512 of the American Recovery and Reinvestment Act requires recipient reporting to be submitted 10 calendar days after the end of each calendar quarter. The first deadline will be October 10, 2009. This requirement is in addition to other reports that you may need to submit to the federal awarding agency.  Failure to comply can have severe consequences including termination of the award. 
In order to meet this requirement, Principal Investigators will receive a Smith College ARRA Reporting Worksheet by email within 15 days prior to a quarter end date.  The report must be completed, by the PI, and returned to Grants Accounting no later than the 5th calendar day following the quarter end date.   In the instance of a subaward, the report must be returned no later than the 3rd calendar day following the quarter end date. Note that the report is Cumulative though the project conclusion.

What needs to be reported?
Grants Accounting will be required to report the following:

  • total amount of recovery funds awarded from each federal agency
  • the amount of recovery funds received that were expended or obligated to projects or activities including:
  • a description of the project or activity
  • an evaluation of the completion status of the project or activity
  • an estimate of the number of jobs created and the number of jobs retained by the project or activity
  • detailed information on any subcontracts or subagreements awarded by the recipient to include data elements required to comply with the Federal Funding Accountability and Transparency Act of 2006.

What do PI/PDs need to know about ARRA funding and reporting?
Information required from PI/PDs

  • Brief description of project
  • Provide quarterly updates on project completion status
  • Provide quarterly updates on the number of jobs created and a description of each job
  • Provide any change of primary place of performance.(where the preponderance of effort takes place)
  • Timely submission of required information

PI/PDs should be aware of the following when managing ARRA funds:

  • Funds from ARRA funding are accounted for separately, even if both are for the same project/
  • Funds should be spent appropriately and quickly
  • Monitor accounts on a monthly basis
  • Avoid large unexpended balances at project end dates.
  • Funds not spent within 12 months may be reallocated by the funding agency.
  • Carry forward of unexpended funds might not be allowed
  • ARRA funds may NOT be carried over to any other project; but a 1 year no-cost extension can be requested for ARRA funded projects.
  • Funds from regular grants may NOT be carried over to ARRA awards.
  • Start up periods during new projects need to be accelerated
  • Hire new personnel as quickly as possible

Detailed information on reporting can be found at www.recovery.gov. The Recipient Reporting Data Model (Data Dictionary) can be found here.  In addition, there is agency specific information

NSF Information  http://nsf.gov/recovery/
NIH Information  http://nih.gov/recovery/
Contact Grants Accounting for more information.  grants@smith.edu

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