Post Award Management Responsibilities
- Principal Investigator
- Department administration ( Department Manager/CAO/Department award analyst)
- Extramural Funds Accounting
- Sponsored Projects Office
Various individuals/groups need to work together throughout the life of an award to effectively manage sponsored research awards on the Berkeley campus. This document describes the primary responsibilities of these individuals/groups once a project has been awarded to the University. All these individuals/groups rely on each other for the successful fiscal management of the award.
The Principal Investigator (PI) serves as the primary individual responsible for the scientific integrity and fiscal and administrative management throughout the period of the award. The PI's specific responsibilities include:
- Being cognizant of, and adhering to, all sponsor-imposed terms and conditions, as well as University policies and procedures related to administering sponsored agreements. (This includes all relevant government and University regulations regarding the use of human and animal subjects, biohazards and bio-safety, occupational health and safety, conflicts of interest, and purchasing and equipment management policies.)
- Obtaining prior approvals from Sponsored Projects Office (SPO) or working with SPO to request prior approval from the sponsor for post-award changes relating to the conduct or scope of the work, and/or budget amendment, expenditure of funds awarded.
- Observing UC and campus policies and procedures to protect intellectual property rights and academic freedom.
- Supervising project personnel including co-investigators, post-doctoral associates, and students (both graduate and undergraduate).
- Submitting technical/programmatic progress reports in a timely fashion to the sponsor as required by the terms and conditions of the award.
- Managing and controlling project funds in a prudent manner and expending funds in accordance with the restrictions imposed by the award terms and conditions and University policy. Funds should only be expended to directly support the project effort and expenditures should not exceed the total amount of funds awarded. Deficits and disallowances incurred against an extramural award account/fund are the responsibility of the principal investigator.
- Advising Extramural Funds Accounting (EFA) and SPO of any cash collections issues or any other information on the financial instability of the agency as soon as they are aware of these issues.
While responsibility for certain day-to-day management of the project finances may be delegated to administrative or other staff, accountability for compliance with the sponsor requirements and University policy ultimately rests with the PI.
Chronic failure to carry out the responsibilities incumbent upon a principal investigator or chronic noncompliance with sponsor regulations, can result in nonpayment of University invoices. Ultimately, this might jeopardize future funding to the PI, as well as to the University as a whole.
Campus departments are responsible for the overall administration of the award. The Principal Investigator (PI) not only is the primary individual responsible for scientific integrity, he/she is also responsible for the fiscal and administrative management of the project. The department Department Manager/CAO will supervise Grant Administrators who will assist the PI in these duties. The department's specific responsibilities include:
- Communicating frequently with principal investigators to keep them apprised of the project's financial business developments and assist them in the administration of awards.
- Providing principal investigators with business and accounting expertise.
- Ensuring that the award's budget in BFS reflects the terms of the agency approved budget.
- Reviewing project expenditures including overhead charges on a regular and timely basis, usually at least once a month. Ensuring the accuracy of overhead charges.
- Reconciling project ledgers on a timely basis and reviewing project financial transactions with the PI. This task should be performed within 30 days after the ledger is available.
- Ensuring that project expenditures are charged in accordance with the terms and conditions of the award and/or University policy. If the direct expenditures of project funds are for costs that would normally be charged indirectly, e.g., clerical and administrative expenses, postage, office supplies, local telephone calls, general-purpose equipment, or operations and maintenance, then those items must have been supported in the proposal by an explicit budget justification and must be included in the final budget awarded by the agency. These direct charges will be allowed only upon sponsor approval. In addition, when administrative and clerical costs are being proposed to a federal sponsor, the proposal must have included an explanation of the activities that allow the project to be classified as a "major project".The proposal must have an explanation of why the charges would be applicable to the project, NOT why the project is a MAJOR project.
- Reviewing ledgers for unallowable costs posted to the award's chartstrings throughout the project period and promptly transferring any unallowable charges to an appropriate chartstring outside of the award. Any questionable charges must be brought promptly to the PI's attention, and, if needed, corrected by an appropriate cost transfer. Transfers should be initiated as soon as possible after a need has been identified. Whenever expenses are moved to or between sponsored award accounts, the PI/Department must assure that the project which ultimately pays the expense is the project which benefited from that expense, and that there is adequate documentation to support the appropriateness of the transfer see Cost Transfer Policy.
- Ensuring that the project complies with all appropriate University payroll, reimbursement, accounting, and personnel policies and practices.
- Monitoring encumbrance balances on a monthly basis and ensuring the balance reflects current purchase obligations for the award and that PO's are closed out on a timely basis.
- Providing PI with regular accounting reports of project balances and expenditures, as well as projections of future expenditures.
- Assisting PIs with all administrative aspects of an award, including maintenance of internal records related to project expenses, activities and reports.
- Ensuring that the PI has approved all appropriate transactions (e.g. cost transfers) in accordance with University polices.
- Ensuring that the percent of salaries charged corresponds to actual time spent on the project.
- Ensuring that effort reports are completed on time and certified by the appropriate official with first hand knowledge of the work performed. See Effort Reporting Policy (pdf).
- Ensuring that the project operates in accordance with its budget. If required, assisting the PI to prepare budget amendments for sponsor.
- Preparing "Departmental Invoices" on awards that require complicated and detail expenditure information for the sponsor.
- Providing the sponsor with detail expenditure support documentations as outlined on the signed contract, in order for the sponsor to release payments on University invoices.
- Advising EFA of any billing issues raised by the agency with the department as soon as they are identified.
- Reviewing monthly Department Manager reports, and advising PI to submit required technical/progress reports or other deliverables to sponsor. Notify EFA of any information on the financial instability of the agency as soon as they are aware of these issues.
- Advising SPO of changes in key personnel specified in the application or award document, (reduction in time and/or absence from the project of key staff, e.g. the PI.)
- Ensuring all capital equipment purchased from award funds appears in the UC Berkeley equipment records Berkeley Equipment Tracking Systems (BETS).
- Ensuring that all requests for no-cost extensions are filed on time with SPO. See No-Cost Extensions.
- Ensuring that all cost share reports are prepared and copies forwarded to EFA. A cost share report must be completed for all NSF awards and forwarded to EFA to allow for compilation of NSF cost share compliance report. See Cost Sharing Policy.
- Advising and assisting the PI in fulfilling the departmental award closeout requirements. See Award Close Out Procedures.Providing documentation for the final financial report to EFA. Departments and the PIs must assure that such documentation is accurate, complete, and readily available.
- Ensuring transfers of any overdraft amounts resulting from unusual circumstances or unanticipated project expenses to the appropriate source of funds is promptly completed prior to close out of the award.
- Ensuring that the project records are kept in good order and are readily available for review and audit.
- Assisting internal and external auditors if required.
Extramural Funds Accounting
EFA is primarily responsible for setting up awards in the Berkeley Financial System (BFS), billing and cash collection throughout the life of the project, coordinating the effort reporting process and preparing financial reports to the agency, primarily at the close out of the award. They provide technical assistance and campus wide training on all aspects of post award management. EFA's specific responsibilities include:
- Setting up of all new sponsored research awards in Berkeley Financial Systems.
- Assigning fund numbers for all new sponsored research awards in BFS.
- Billing all agencies (including other UC campuses) in accordance with the award invoicing terms.
- Responding to other UC campuses' invoices timely.
- Preparing letter of credit draw downs throughout the life of the award.
- Managing internal accounts receivable system to assure data integrity.
- Applying check payments and wire transfer of funds accurately to outstanding accounts receivable.
- Resolving unidentified payments from the sponsor timely.
- Researching and resolving any credit balances in accounts receivable.
- Providing monthly accounts receivable report to the department on unpaid invoices.
- Providing monthly accounts receivable report to SPO on unpaid invoices due to non-submission of technical/progress reports and deliverables from PI, and other contractual disputes.
- Conducting cash collection for all receivables on UCB contracts and grants.
- Calculating and posting all overhead charges to the awards.
- Managing the encumbrance balances on all intercampus sub awards.
- Coordinating the effort reporting process throughout the life of the award.
- Coordinating the financial close out of the award.
- Preparing final reports to the agency.
- Inactivating the award fund in BFS.
- Performing post audit reviews on award transactions.
- Preparing financial year end closing entries and financial schedules reporting to external auditors and the Office of the President for the fiscal close.
- Coordinating all external audits on awards.
- Conducting campus wide training in post award management.
Sponsored Projects Office
The Sponsored Projects Office (SPO) at the Berkeley campus is responsible for preparing, interpreting, negotiating, and accepting agreements for projects funded by federal, state, and local government agencies, foundations, corporations, and other public and private sources. SPO also prepares and negotiates all subawards for collaborative research. SPO's specific responsibilities during the post award management process include:
- Advising the PI and project personnel during the period of the award regarding their obligations under the terms and conditions of the award. Informing the PI and unit administrator about the actions that will need to be taken to meet the commitments under the terms and conditions of the award including subcontracting, patent rights, copyrights, rights in data, license agreements, publication rights, transfer of materials, etc.
- Serving as the office of record for all awards made to The Regents of the University of California on behalf of the Berkeley campus.
- Advising faculty and staff regarding the sponsor's and University's prior approval requirements for changing aspects of the project, (i.e., changes in PI, changes in the scope of work, reduction in PI time devoted to the project or absence from the project funding changes, no-cost time extensions, etc.).
- Coordinating and advising agencies of any special requirements related to sponsor notifications during the life of the award, e.g. scope changes, funding changes, key personnel changes, and reduction in PI time devoted to the project or absence from the project. Coordinating and negotiating these changes with the sponsor and as necessary accepting or executing modifications to the award to effectuate these changes.
- Reviewing award changes to ensure that the scope of work and terms and conditions are acceptable to the principal investigator and are consistent with University policies. Accepting or executing modifications to sponsored agreements (grants, cooperative agreements or contracts) on behalf of the Regents of the University of California.
- Distributing the award documents and award synopsis to the principal investigator and appropriate academic and administrative units.
- Interpreting sponsor policies, University policies and federal and state regulations related to the terms and conditions of the award, the conduct of the project and the delivery/reporting of project results.
- Serving as a liaison between the principal investigator, project staff, administrative unit staff, and the sponsor.
- Assisting EFA collection staff on unpaid University invoices by sponsor, due to non-submission of technical/progress reports and other required deliverables by PI; and disputes on contractual terms.
- Monitoring and coordinating the submission of project reports required by the terms of the award and the administrative closeout of the project when the award expires. Assisting in the completion of all closeout procedures as necessary.