The principal investigator (PI), senior project personnel and affiliated research administration staff are responsible for ensuring that only allowable costs related to the project are charged or transferred to the sponsored project and are responsible for monitoring any subrecipients. NC State University utilizes a combination of the PI Portal and Enterprise Application Services to track and monitor expenditures on sponsored projects. Monitoring is necessary to ensure that all charges posted to the project are accurate, allowable and correctly identified using the appropriate account codes. Additionally, monitoring facilitates the preparation of accurate and timely financial reports during project closeout.
What to Consider:
- Total Budget – Ensure total budget amount on any internal reconciliation spreadsheet matches budget total in Financials (WRS) for the Project. Total project budget (inclusive of parent and all associated segments) in WRS should match the total award amount listed in award documentation (RADAR).
- Monthly Expenditures – Ensure total reconciled expenditures for the month matches Current Month Activity in WRS and backup documentation is maintained to support all charges: communication with PI regarding planned level(s) of effort allocated to a project (whether charged directly or not), approvals of non-personnel expenses, Purchase Order history, contractual arrangements, etc. to support the charges allocated to the project.
- Review/Verification of PI and Key Personnel Payroll Projection – Are there discrepancies where actual and committed levels of effort are concerned? If so, communication with PI is necessary to make necessary salary / cost-share adjustments. Depending on the specific situation, it may be necessary to initiate communication with the assigned Fiscal Manager in the Office of Contracts and Grants.
- Project Non-Personnel Review – Review all non-personnel expenditures charged to the project. Are there charges which may be deemed unallowable by review of approved budget, award terms and conditions or other federal or state (including NC State University) guidelines? Be certain to highlight — for PI review — such questioned charges. Should the determination be made that certain charges are unallowable, these should be moved to an appropriate funding source in a timely manner.
- As Applicable – Is the appropriate cost share being charged for salary cap and/or other cost-share commitments associated with the project? Report to the PI that cost-share commitments have been reviewed and are on target, or discuss correction needed as appropriate. Recording cost-share history and projections in spreadsheet format is recommended to ensure commitments are met and to provide to PI for verification.
- Total Expenditures – Ensure total expenditures charged to the project through the current month-end reconciliation agree with what is being reported in WRS. Any discrepancies should be investigated and corrected.
- Budget Modification – As needed (utilizing award specific terms and sponsor guidance), work with the Office of Contracts and Grants to update the project budget to reflect changes in planned spending. This is especially important when changes involve categories such as equipment, tuition and subawards — where indirect costs might possibly be impacted.
- Overall Projection Review – Analyze the internal budget plan vs. incurred and projected expenses. Provide clear documentation in transmission email to PI of any areas in which they should comment, review in detail, or provide guidance, such as: large (greater than 25% for NIH) projected balances, projected payroll well under/over budget, projected non-personnel categories well over/under budget, expenses in unanticipated categories, especially high-profile categories such as animal-use charges, post-doc tuition, health insurance, travel, equipment, etc.
Policies and Guidance
It is essential that researchers and research staff at NC State adhere to the policies and guidelines that are important to conducting research. There exists a range of policies and guidance for requesting, accepting, and managing external funding and conducting sponsored projects.
Changes from the project workplan and budget included in sponsored project terms and conditions — whether allowed internally or which require sponsor approval — must be formally documented via a Project Modification Request (PMR).
Sponsors award funding with the expectation that the named investigator will be responsible for directing or overseeing the project. Prior approval is required if any key person withdraws from the project, is absent for any continuous period of three months or more and/or reduces the level of effort devoted to project by 25% or more from what was approved in the initial award.
The university may request a change in PI on a grant for any of the following reasons:
- The PI transfers to industry or to another institution and is ineligible to continue the project.
- The university that the PI is transferring to is ineligible to receive funds.
- Untimely death, serious illness or injury renders the PI unable to continue work on the project.
- Significant change in the PI ability to work on the project (i.e., major reduction in percent of effort, etc.)
- Change of circumstances that require the PI’s continued absence from the university or project for more than three months (e.g., sabbatical or military leave).
- Other circumstances that, in the opinion of the university, necessitate a change in PI.
A detailed justification must be provided explaining how the change will affect the overall project, effective date of the change, purpose of the change and qualification of the New PI (CV/resume and Current/Pending Report). These requests must also be approved by the department head prior to routing to SPARCS for review and processing.
The budget is the financial expression of the project or program as approved during the award process. It is not uncommon for a PI to determine that for efficient performance of the project, they must rebudget funds from one budget line or category to another. Some sponsors have delegated this authority to the university to approve these types of changes or modifications. Some sponsors require the university to formally submit a budget modification that explains both the need and the anticipated impact, if any, on the outcome, scope or purpose of the work. The justification should describe how the proposed budget modification will affect the technical purpose or scope of the project, contain a brief explanation of why the proposed budget modification was not planned originally, and why other budgeted funds are now available for this purpose and the intended use of the funds. A budget modification request can be submitted to re-align the funds within specific budget categories, which might require agency approval. A budget modification request can also be submitted to move funds between Project Segments.
- For NIH modular awards, each notice of award (NOA) sets forth the amount of funds awarded. The amount may be shown either as a categorical (i.e., line item) budget or as an amount for total direct costs (i.e., not broken down by category) and an amount for indirect costs, if applicable. Modular awards represent a type of award made without a categorical budget (see Modular Applications and Awards chapter in IIB). The recipient has certain rebudgeting flexibility IIA-59 Part II: Terms and Conditions of NIH Grant Awards – Subpart A 5 The Notice of Award within the overall amount awarded (see Administrative Requirements—Changes in Project and Budget). Read the NIH Grants Policy Statement to learn more.
- For NIH non-modular grants, significant rebudgeting can occur whether or not the particular expenditure(s) require prior approval. Significant rebudgeting occurs when expenditures in a single direct-cost budget category deviate (i.e., increase or decrease) from the categorical commitment level established for the budget period by 25% or more of the total costs awarded. For example, if the award budget for total costs is $200,000, any rebudgeting that results in an increase or decrease of more than $50,000 in a direct-cost budget category is considered significant rebudgeting. The base used for determining significant rebudgeting excludes the effects of prior-year carryover balances but includes competing and non-competing supplements. Significant rebudgeting does not apply to modular grants. Learn more from the NIH Grants Policy Statement.
- For non-NIH sponsors, Contracts and Grants will check grant guidelines to determine when prior approval is required for rebudgeting.
- FDP Prior Approval Matrix
If the department is requesting early termination, an Other PMR should be submitted. In certain instances, a project may terminate prior to the original expiration date; for example, due to:
- PI leaving the institution and the project not being transferred or assigned a new PI
- Loss of federal funds or sponsor requesting termination
- Sponsor sending a Stop Work Order or Notice of Suspension
Award agreements typically include a clause for how an early-termination situation will be handled. Generally, such notices would be sent by the sponsor to SPARCS, who should contact the Grant Business Officer (GBO) immediately. If the notice is sent directly to the PI, a copy should be forwarded to SPARCS immediately. SPARCS will work with the GBO to evaluate the notice and plan a formal response to the sponsor.
Equipment refers to tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost which equals $5,000 or more. The purchase of capital equipment (i.e., equipment with a unit cost of $5000 or more) often requires prior approval by the sponsor if:
- the purchase of capital equipment was not included in the award budget, or
- the PI or PD wishes to purchase a piece of capital equipment different from that included in the award budget.
Provide a generalized specification (i.e., cost, description) and justify the need for the equipment in relationship to the statement of work (i.e., why the equipment is needed). Equipment should not be purchased within the last three months of the project. These requests must also be approved by the department head prior to routing to the Contracts and Grants for review and processing. Departments need to ensure the equipment does not currently exist on campus. The department head is financially responsible for the cost of the equipment if the request is denied.
Fabricated equipment is defined as an item of equipment that is built or assembled in its original form from individual parts by a PI and/or other sponsored project personnel, an internal shop, or an external entity. If a fabricated equipment item will have an aggregate cost of less than $5,000, the individual costs for all acquisitions are subject to the relevant indirect costs rate. If you initially anticipate that the total fabrication will cost more than $5,000 and, as such, exempt the individual components from indirect costs but the final product cost is less than $5,000, then all component costs will then be subject to indirect costs. An instance where components are simply connected together in a system, such as when individual computers and servers are joined to create a network, does not constitute a fabrication.
A subaward is an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out a portion of the project. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract.More about Subawards
An audit is a verification of compliance. Audits are conducted to provide assurance that project reports do not contain material misstatements, to assess the strength of internal controls and to provide assurance of the recipient’s compliance with requirements governing the use of funds.
Audits can be programmatic or financial and involve different types of testing and assessments, depending upon the audit purpose, source of funding and auditor affiliation. Any project is subject to audit.
If you are contacted by a sponsor about an audit of any sort, email email@example.com.
At times, sponsors require some form of invoicing from NC State in order to issue payments. The three forms of invoices are:
The department incurs expenses and NC State invoices the sponsor based on actual expenditures. These invoices are issued in accordance with the sponsored agreement invoicing timeline. Please review your budget regularly to confirm expenditures are posting correctly. This ensures that invoices accurately reflect award activity.
The sponsor issues payments on a set schedule regardless of the department’s expenditure level or deliverables completed. When required, NC State issues invoices to trigger these payments.
The sponsor pays based on the completion of the deliverables listed in the award agreement. The department must contact the fiscal manager in Contracts and Grants (C and G) when a deliverable is met to notify them that an invoice is due.
- At point of proposal: Use published conversion rates (e.g., OANDA.com) to estimate the USD equivalent of the foreign currency being requested. Include both the budget proposed in a foreign currency and the USD budget in the proposal record.
- At point of award: The ledger 5 budget will be loaded in USD in an amount based on the current (date of set-up) conversion rate. Remember this is still an estimate of the USD value of foreign currency to be received. The college must assume the risk of unfavorable currency fluctuations, wire fees and any transaction fees that apply.
- If the sponsor will provide full payment when the award is issued, the account can be set up with or promptly revised to the converted USD amount for the award. This minimizes the college’s risk. Awards with a substantial payment after the final report or deliverable is received carry the greatest risk.
- When payment is received: Revenue will be recorded in the actual USD received. If the sponsor pays in installments, each payment will be converted to USD when received, based on the conversion rate at that time. C and G will apply the converted dollar amounts received in each payment.
- Account closeout: At account closeout, expenditures must be reconciled to total USD received for the project. Any shortfall is the college’s responsibility.
Occasionally, a sponsor’s desired invoice format requires departmental input, such as the PI’s signature or a summary of the work completed during the invoice period. The unit is responsible for providing the information needed for the invoice to C and G.
The department must notify C and G when a milestone deliverable has been completed.
- Sponsors may require a level of backup on every invoice that C and G cannot provide (e.g., copies of all receipts).
- Sponsors may also request ad hoc backup for an individual invoice. This is most common when there are unexpected charges (e.g., expenditures in categories not included in the award budget or much higher or lower expenses than in previous periods) or when there are travel charges. If the sponsor contacts the unit directly, please contact C and G.