Roles and Responsibilities in the Administration of Grants at UMSL

1. Roles and Responsibilities in the Administration of Grants at UMSL University of Missouri Policies & Procedures

2. Responsible Parties • Principal Investigator (PI/Co-PI) Named by sponsor on award document with overall responsibility to manage the award. • Department Administrator (Dept Admin) Individual in the department assisting PI with the fiscal management of an award. • Office of Research Administration (ORA) Campus office monitoring compliance with applicable regulations, policies, and terms and conditions of the award. See Business Policy Manual, BPM 210 Sponsored Programs

3. High Level Roles & Responsibilities Principal Investigator The University of Missouri assigns primary responsibility for fiscal management to the Principal Investigator (PI),which is in the spirit of both federal regulations, individual sponsor guidelines, and university policies and procedures. Per current UM System policies, PIs are responsible for: • All expenditures made against a sponsored project • Knowing and adhering to the specific limitations and restrictions of the sponsor and of the award documents • Knowing and adhering to all administrative and financial compliance requirements of sponsors, regulators and the University

4. High Level Roles & Responsibilities Department Administrator Department Administrators are responsible for: • Providing support to PIs in the administration of awards • Knowing and adhering to all administrative and financial compliance requirements of sponsors, regulators and the university

5. High Level Roles & Responsibilities ORA The Office of Research Administration (ORA) is responsible for: • Reviewing proposals to ensure they meet agency requirements before submission • Overall budget within the guidelines • Risk-assessment if budget exceeds $3 million • Evaluation of sources of cost share, if any • Overseeing regulatory compliance of proposals • IRB, IACUC, conflict of interest, and export control compliance • Ensuring fiscal compliance with sponsor and University policies and procedures (e.g., financial reporting, milestone tracking, invoicing)

6. Roles & Responsibilities in Proposal Development and Submission (Pre-award)

7. Roles & ResponsibilitiesPrincipal Investigator < General Pre-Award Responsibilities > • Development of proposal • Proposal narrative, scope of work • Financial budget and justifications • Approvals – Proposal Signature Routing Sheet, PSRS (aka, signature page) • Refer to ORA website for institutional information • Proposal Submission to the ORA • Minimum of two weeks prior to deadline • Extra week if budget is above $3 million ORA reviews and submits – PI does not submit directly

8. Roles & ResponsibilitiesPrincipal Investigator < Pre-Award Responsibilities: Proposal Development > The PI’s general responsibilities in proposal development include the following: • Ensure sponsor requirements and guidelines are met • Forms • Unique allowability restrictions • Submission deadline • Compliance with University policies • Accounting Policy Manual (APM) – Section 60 • Business Policy Manual (BPM) – Section 210

9. Roles & ResponsibilitiesPrincipal Investigator < Pre-Award Responsibilities: Budget > • Allowable direct costs per A-21 and sponsor • Reasonable • Allocable • Consistent treatment • Conform to limitations or exclusions of sponsor • Justify any unlike circumstances • Reasonableness of effort commitment • Evaluate with existing commitments

10. Roles & ResponsibilitiesPrincipal Investigator < Pre-Award Responsibilities: Budget > • Use of subawards • Include in budget and scope of work • Properly identified • Subject to same compliance requirements • Obtain letter of commitment and budget from sub-awardee grants office • Use appropriate F&A rate • Approval required for any waivers from VPR (rarely approved)

11. Roles & ResponsibilitiesPrincipal Investigator < Pre-Award Responsibilities: Budget > • Cost sharing requirements • Cost share should be included only when required or suggested • Must be an allowable direct cost • Committed cost share must be approved • Evaluate for reasonableness • Ensure all cost sharing is clearly identified – direct or implied • If award is received, all committed cost share must be allocated and documented appropriately

12. Roles & ResponsibilitiesPrincipal Investigator < Pre-Award Responsibilities: Compliance > • Conflict of Interest disclosures • Human Subjects – Institutional Review Board (IRB) • Institutional Animal Care and Use Committee (IACUC) • Export Control regulations • Intellectual property potential • Responsible conduct of research training

13. Roles & ResponsibilitiesDepartment Administrator < Pre-Award Responsibilities: Proposal Development > The Department Administrator: • Assists with review of proposal for compliance • Reviews budget for allowable costs • Identifies need to justify unlike circumstances • Ensures PSRS is signed by appropriate individuals

14. Roles & ResponsibilitiesORA < Pre-Award Responsibilities: Review & Submission > Before submission, the ORA reviews for: • Compliance with submission requirements • Proposal budget calculations • Allowable costs and budget justification • Risk assessment if budget is over $3 million • Appropriate approvals on the PSRS • The ORA obtains institutional endorsement The ORA is responsible for formally submitting the proposal.

15. Roles & ResponsibilitiesProject Establishment • The PI evaluates need for a Pre-Award Project Account and submits a request to the ORA • Criteria to establish an account prior to award: • Proposal must be under review • PI, Department Head and/or Dean guarantee costs • Justification to begin work before award receipt • Other approvals required (e.g., human subject)

16. Roles & ResponsibilitiesProject Monitoring • The ORA monitors Pre-Award Projects that are: • Older than 90 days (discusses status with PI) • Older than 6 months (determines appropriate action) • Upon award execution, the ORA: • Changes status from Pre-Award to Awarded • Reviews pre-award projects to ensure spending is properly reflected

17. Roles & Responsibilities Accepting & Establishing an Award for Sponsored Programs (Post-Award)

18. Roles & ResponsibilitiesPrincipal Investigator < Post-Award Responsibilities: General > Upon receipt of the Notice of Grant Award (NGA), the PI: • Notifies all appropriate individuals (e.g., ORA, sub-awardees, CoPIs, Dept Administrator) • Determines whether to accept award • Reviews and approves the NGA • Creates a revised budget if necessary • Conducts technical and programmatic negotiations

19. Roles & ResponsibilitiesPrincipal Investigator < Post-Award Responsibilities: General > Once award is fully executed, the PI: • Delegates authorization to: • Dept administrator or other applicable persons who are university employees with direct knowledge of the award and related compliance requirements • Determines payroll distribution • Identifies non-owned assets/equipment in the award • Reviews expenditures posted to the grant on monthly basis The PI has overall responsibility to manage the award.

20. Roles & ResponsibilitiesPrincipal Investigator < Post-Award Responsibilities: Regulatory > The PI ensures regulatory requirements are in place: • Conflict of Interest disclosures • Human Subjects – Institutional Review Board (IRB) • Institutional Animal Care and Use Committee (IACUC) • Export Control regulations • Intellectual Property • Responsible Conduct of Research training

21. Roles & ResponsibilitiesDepartment Administrator < Post-Award Responsibilities: General > Upon receipt of the NGA, the Department Administrator assists with: • Notifying all appropriate individuals • Creating a revised budget if needed When the fully executed award is established, the Dept Admin: • Verifies the budget information in the financial system • Sets up payroll distributions • Ensures award funded non-owned assets/equipment are identified • Reviews expenditures on monthly basis and issues reports to the PI as deemed necessary

22. Roles & ResponsibilitiesORA < Post-Award Responsibilities: General > Upon receipt of the NGA, the ORA reviews for: • Award consistency with proposal • Compliance with University policies • PI approval and acceptance of NGA • Completion of regulatory approvals

23. Roles & ResponsibilitiesORA < Post-Award Responsibilities: General > Before award acceptance, the ORA: • Conducts fiscal, business, and legal negotiations • Notifies sponsor of changes in: • Project scope • Budget • Cost sharing • Facilities and Administrative (F&A) rate • Other legal clauses • Other changes at PI‘s direction

24. Roles & ResponsibilitiesORA < Post-Award Responsibilities: General > After award is fully executed, the ORA: • Notifies appropriate individuals • Establishes award in the financial system including • Project ChartField string • Budget information • Subawards • Cost sharing commitments • Catalog of Federal Domestic Assistance (CFDA) and Schedule of Expenditures of Federal Awards (SEFA) cluster • Billing information • Milestones for report due dates • Ensures award funded non-owned assets/equipment are identified and tracked

25. Roles & Responsibilities Allowable Costs: A-21 Effort Verification Reporting (EVR) Cost Sharing General Cost Transfers and PCEs

26. Roles & ResponsibilitiesA-21: Allowable Costs

27. Roles & ResponsibilitiesEVR

28. Roles & ResponsibilitiesCost Sharing

29. Roles & ResponsibilitiesGeneral

30. Roles & ResponsibilitiesCost Transfers & PCEs

31. Roles & Responsibilities Closing Sponsored Awards

32. Roles & ResponsibilitiesPrincipal Investigator < Closing Sponsored Awards: Final Review > • Ensures all costs charged to award are: • Allowable • Within period of availability • Documented • Identifies outstanding charges • P-card • Feeder systems (e.g. telecommunication) • Clears deficits • Ensures cost transfers are made timely

33. Roles & ResponsibilitiesPrincipal Investigator < Closing Sponsored Awards: Final Review > Ensures compliance requirements are met for: • Committed Effort - PI and key individuals • Example: PI - 25% reduction in effort or 3 month absence • Significant changes of key individuals • Subawards – final invoices and deliverables received • Cost sharing commitments • Mandatory and voluntary • Changes in category of cost share from award • Other requirements per award agreement • Program income

34. Roles & ResponsibilitiesPrincipal Investigator < Closing Sponsored Awards: Final Review > • Evaluates need for no-cost time extension • Completes PI Certification • Signifies all costs are allowable per A-21 and/or sponsor • Submits technical and programmatic reports • Reporting period will vary by sponsor • Provides intellectual property notices

35. Roles & ResponsibilitiesPrincipal Investigator < Closing Sponsored Awards: Administrative > • Updates payroll distribution (PAFs) • Cancels P-cards and feeder systems • Retains documents for required period • PI retains scientific data • Department retains transactional data • Returns non-University owned assets to sponsor

36. Roles & ResponsibilitiesDepartment Administrator < Closing Sponsored Awards > Assists PI in closing of award: • Ensuring costs are allowable and documented • Timely addressing items such as: • Cost transfers, Payroll Correcting Entries (PCEs) • Updating payroll distribution (PAFs) • Cancelling P-cards and feeder systems • Closing purchase orders, open encumbrances • Returning non-University owned assets to sponsor

37. Roles & ResponsibilitiesORA < Closing Sponsored Awards: Final Review > • Works with unit to close out award • Conducts high-level compliance review to ensure: • Terms and conditions met • Subaward invoices received and paid • Deficits cleared • Technical report completed • Reasonableness of cost transfers • Costs are allowable and inline with budget

38. Roles & ResponsibilitiesORA < Closing Sponsored Awards: Administrative > • Submits final invoice to sponsor • Excess funds de-obligated • Reconciliation of program income • Documentation for permanent file • Proposal, Award, EVRs, invoices, programmatic, technical and financial reports, sub-award documentation, etc. • Confirms non-owned assets/equipment returned to sponsor • Completes transfers on fixed-price contracts • Inactivates project in financial system • Submits final financial report to sponsor

39. MORE INFO Office of Research Administration www.umsl.edu/services/ora 314-516-5899