Grants Administration

When the college receives an award notice the process moves from a pre-award to a post-award stage. Grants administration works closely with the sponsored research office to ensure the smooth transition from pre-award to post-award activities, and with principal investigators and staff in the post-award administration of those awards.

Grants administration 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 administration will highlight any special terms and conditions, such as restrictions, and requirements, as well as verify the elements of the agreement.

If necessary, grants administration 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.

The PI/PD is responsible for monitoring all expenses charged to the grant. We recommend 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 BannerWeb (via the Smith Portal).

All non-compensation expenses allocated to any sponsored project are reviewed and approved by grants administration 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 administration after they have been posted (see ProCard Expenses). An expense is allowable on a sponsored project if it meets the following criteria:

1. Reasonable—a prudent person would have purchased this same item and paid same price; an arms-length arrangement.
2. Allocatable—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.
3. Consistently Treated—like expenses are treated the same by the institution given same circumstances.
4. 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 CFR 200 - UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS. If you have questions regarding the allowability of an item, you are encouraged to contact grants administration prior to placing the purchase.

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.

College ProCards may not be set up to directly default to an external grant. If any grant-related charges are made on a college ProCard, the expense must be reallocated to the grant by following the appropriate procedure and approval process.

Grants administration 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 regular 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. Please refer to the Cost Transfer Policy for clarification as to what expense transfers qualify as 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 administration 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.

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 form.

Grants Administration prepares all financial reports required by the sponsoring agency. Do not provide any financial information to a sponsor without verification by the Assistant Director of Grants Administration.

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 Administration. Copies of all narrative reports and correspondence related to institutional grants should be forwarded to the Office of Corporate & Foundation Relations.

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 Administration will close-out the fund according to the Close-Out of Fixed Price Agreements instructions.

After all internal and external requirements have been met, Grant Administration will begin the grant close out process documented in the Grant Closeout Checklist and will begin the record retention period of the grant file.

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 administration 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 various 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
• 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 (specific to National Science Foundation awards)

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 by grants administration.

Many federal agencies have transferred the authority to approve such changes to awardee institutions. If the principal investigator wishes to modify the awarded budget or make another administrative change to their grant, they should contact grants administration for the proper procedure to do so. The actual request for change must be made in writing either using the Prior Approval Request Form.

Subrecipients submit invoices directly to grants administration. After initial review grants administration will forward the invoice to the principal investigator for approval. Once the PI has approved it, the invoice is returned to grants administration 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.

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, including student workers.

All employees working on a federal contract for Smith College must complete a Form I-9. The Offices of Human Resources and Payroll will ensure that all Smith employees and students working on federal contracts are processed in the E-Verify system.

Participant support costs are costs to support individuals who are receiving a training opportunity as part of a workshop, conference, seminar, symposium or other short-term instructional or information sharing activity funded by a sponsored award. Costs may include stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants (not employees). A participant does not perform work or service for the project or program. The participant is not required to deliver anything or provide any service to the university in return for these support costs.

Unallowable costs are defined by Smith College as those expenses which are not reimbursable under the terms and conditions of federally sponsored agreements and/or those specifically identified as unallowable in 2 CFR 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”), published by the United States Office of Management and Budget (OMB).

Procurement: Smith College has adopted the new Uniform Guidance (CFR Title 2: Grants and Agreements PART 200) as of 12/26/14, but chooses to postpone the adoption of the procurement regulations until FY 2019, beginning July 1, 2018.