Post-Award Steps

·         Funding Decision

o   Notice directly to PI, PI submits Notice to RASP

o   Notice directly to RASP, RASP will communicate to PI

·         If Funding Decision to is Award, PI works with RASP

o   Submit Award Notice

o   Fill out Request for New Grant Account Form

o   RASP forwards to Grants Accountant

Go on to Step 3

Go on to Step 4

Go on to Step 5

Understand allowable, allocable, and reasonable costs

The concepts of allowability, allocability, and reasonableness of costs address directly the legitimacy of a cost charged against a specific sponsored research award. Determination of allowability, allocability, and reasonableness of a given expense is based on specific guidelines of the funding agency and according to federal cost principles, 2 CFR Part 200, Subpart E - Cost Principles of Uniform Guidance.

 Allowability, allocability, and reasonableness are defined and determined by the Office of Management and Budget (OMB) following the sponsor's requirements and University policy. Each financial transaction charged against a sponsored research award is evaluated against the following three concepts: 

o    Allowability; costs must be reasonable, must be given consistent treatment through application of those generally accepted accounting principles appropriate to the situation, and conform to any limitations or exclusions set forth in the sponsored agreement or in the Federal Cost Principles (OMB Uniform Guidance §200.403).

o    Allocability; cost has been incurred solely to support or advance the work of a specific sponsored research award or realistic proportioned and charged to multiple projects, in reasonably and equitably.

o    Reasonableness; cost of an expenditure that doesn't exceed the amount a person using good judgment and common sense would have spent under the circumstances to purchase the items.

The PI(s), Research and Sponsored Programs (RASP), and the Grants Accountant work together to ensure that all costs charged to the sponsored research award are allowable and allocable based on specific guidelines of the funding agency and according to federal cost principles.

 Understand allowable and unallowable costs

o   Allowable costs (for all non-federal entities, other than for-profit entities and hospitals) are those costs consistent with the principles set out in 2 CFR 200, Subpart E, and those permitted by the funding agency’s  authorizing legislation. The fact that a cost requested in a budget is awarded, does not ensure a determination of allowability.

o   Unallowable costs are costs that will not be supported by a funding agency or will not be reimbursed. If a cost cannot meet the criteria of allowability, allocability, and reasonableness, it is unallowable. A funding agency’s program announcement may identify costs which cannot be included in the budget, although they may qualify as direct costs according to Code of Federal Regulations. Funding agencies may also limit amount in certain budget categories.

Common Categories of Allowable and Unallowable Costs: 

Develop your project management plan

Review and monitor your award budget 

It is expected that the PI or their delegate will review the fiscal status of their sponsored project budget(s) regularly and promptly correct expense transactions that are incorrectly* recorded. 

*The University recognizes that a correction, also known as a cost transfer, from one account to another are occasionally necessary to correct bookkeeping or clerical errors in the original charges. If a need for a correction to or from a sponsored project budget arises, the PI must notify the Grants Accountant [KS1] in writing as soon as possible. Written notice should include details and justification for the correction request. The Grants Accountant will review allowability of correction request for alignment with the terms of the sponsored award, then facilitate correction in consultation with RASP, where needed. 

Using your STAR ID and password, log into WorkDay (the online accounting application) to access your project budget. The Accounting Application offers an interactive platform for reviewing and monitoring your projects budgets. For guidance and detail on running reports, please refer to the helpful crosswalk resources on the Grants and Contracts page and/or the Accounting Reports Instructions (both on the Fountain).

Facilitate project expenditures 

External sponsors expect that costs are charged appropriately at the time incurred and that significant adjustments should not be required if adequate financial management practices and policies exist. 

Procedures for hiring and purchasing are the same for all University expenditures, including sponsored projects. Please refer to the facilitating expenditure page for details on how to process expenses associated with your sponsored project.

·       Complete the Post-Award Modification Request Form and submit to RASP early enough to allow time for administrative processing and to secure sponsor approval in advance of the request change and the award end date.

Once the program officer has been consulted and all internal approvals are secured, RASP will submit the request to the sponsor for approval. If approved by the sponsor, a notification of approval or an amendment will be issued to Minnesota State University, Mankato.

The following are the most common types of award modifications; please see each section for specific PI(s) action steps.

• No-cost Extensions

A no-cost extension extends the project period beyond the original project end date and involves no additional funding. If you anticipate not being able to complete your research by the end date of your award, an extension may be allowable if the following conditions are met:

• • There is a programmatic need to continue the research, AND
  • There are sufficient funds remaining to cover the extended effort
  • Note: Remaining budget balance alone is not justification for an extension.

PI Action Steps:

1. Notify RASP regarding modification as soon as the situation is known.

2. In accordance with funding agency guidance: prepare justification, define the proposed new end date, and outline how remaining budget balance will be used.

3. As appropriate, consult department chair and Dean regarding requested modification.

4.For projects with co-Principal Investigator(s), discuss requested modification among project team prior to proceeding to step 5.

5.Complete and submit Post-Award Modification Request Form to RASP.

Once received, a modification request is reviewed by Research and Sponsored Programs. Further information will be collected from the PI, and PI’s department and dean/supervisor, as needed. Upon internal review and approval, Research and Sponsored Programs submits the modification request to the funding agency. Once the agency approval is documented, modification specifics will be shared with the Grants Accountant to ensure the University’s official award file remains current.

• Budget Revisions

After a grant or contract has been awarded, the PI may determine that the approved budget allocations are not consistent with actual project needs and may request the formal reallocation of funds from one spending category to another to complete the project requirements and implementation. Funding agencies will often consider budget revision requests.

PI Action Steps:

1.Notify Grants Accountant and RASP regarding modification as soon as the situation is known.

2. In accordance with funding agency guidance: draft a revised budget spreadsheet, including justification for the revision and impacts to the project.

3. As appropriate, consult department chair and Dean regarding requested modification.

4. For projects with co-Principal Investigator(s), discuss requested modification among project team prior to proceeding to step 5.

5.Complete and submit Post-Award Modification Request Form.

Once received, a budget revision request is reviewed by the Grants Accountant. Further information will be collected from the PI, and PI’s department and dean/supervisor, as needed. The Grants Accountant, in consultation with RASP, determines if the budget revision request requires a formal award modification, and if required, a formal budget revision request will be submitted to the funding agency. Once approval is documented, modification specifics will be shared with the Grants Accountant and RASP to ensure the University’s official award file remains current.

• PI/Key Personnel Changes

The approval of the project has been based on the participation or qualifications of the PI(s) and other key personnel. Thus, the sponsor requires notification whenever there is a significant change in the level of participation by the PI(s)/key personnel. The sponsor has the option to either approve or disapprove of any personnel changes on an award.

Examples of circumstances of when PI/key personnel changes are needed:

o    Termination of affiliation with Minnesota State University, Mankato

o    Significant change in the percentage of effort (25% or more) that they are available to work on the project

o    Change of circumstances that requires continued absence from the university or project for more than 3 months (sabbatical, leave of absence, etc.) - See Disengagement of PI for 90 Days or more section below

o    Unforeseen circumstances (serious illness/injury, etc.) that prevents continuation of work on the project.

PI Action Steps:

1.Notify RASP regarding modification as soon as the situation is known.

2. As appropriate, consult department chair and Dean regarding requested modification.

3.For projects with co-PI(s), discuss requested modification among project team prior to proceeding to Step Four (4). Prior to contacting the program officer, those projects that are collaborative projects with multiple co-PIs from different colleges, we recommend that the PI discuss proposed personnel changes with the co-PI(s) and the college Deans.

4. After consultation with the project team/Deans, and the program officer, complete and submit Post-Award Modification Request Form online

Once received, a modification request is reviewed by RASP. Further information will be collected from the PI, and PI’s department and dean/supervisor, as needed.  RASP submits the modification request to the funding agency. Once approval is documented, modification specifics will be shared with the Grants Accountant to ensure the University’s official award file remains current.

• Disengagement of PI for 90 days or more

Funding agencies reasonably expect that the PI will be present when a funded project is implemented to manage the award and ensure that objectives and timelines are fulfilled. If the PI retains their affiliation with Minnesota State University, Mankato but will be disengaged for 90 days or more (e.g., sabbatical, leave of absence, etc.), the sponsor's guidelines about reporting and managing the absence will be followed. Generally options include:

o   If the PI chooses and can successfully supervise/manage the project and be actively involved form a remote location, the sponsor may consider this a viable option OR

o   If the PI is going to be disengaged from their project, the sponsor may consider a substitute PI to complete the project. Typically, once the sponsor approves a substitute PI, the change will be in effect throughout the life of the award or until another modification is requested (i.e. the original PI returns to the project).

PI Action Steps:

1. Notify RASP regarding modification as soon as the situation is known.

2. As Appropriate, consult cognizant department chair and Dean regarding requested modification.

a.   In collaboration with the department chair and Dean, if PI substitution will be pursued, a new PI will be identified to be proposed to the sponsor.

b.   The new PI will need to complete required forms, e.g. Conflict of Interest, corresponding agency documents, etc.

3. For projects with co-PI(s), discuss requested modification among project team prior to proceeding to Step Four (4). Prior to contacting the program officer, those projects that are collaborative projects with multiple co-PIs from different colleges/schools, we recommend that the PI discuss proposed personnel changes with the co-PI(s) and the college Deans.

4. After consultation with the project team/Deans, and program officer, complete and submit Post-Award Modification Request Form.

Once received, a modification request is reviewed by RASP. Further information will be collected from the PI, and PI’s department and dean/supervisor, as needed. RASP submits the modification request to the funding agency. Once approval is documented, modification specifics will be shared with the Grants Accountant to ensure the University’s official award file remains current.

• Other

There are a variety of alternate reasons for award modifications. Some examples include, but are not limited to:

o    Change in project scope

o    Purchase of equipment during the last 3 months of award

o    Transfer award to another institution

• o    For other modifications (contact RASP to discuss)

PI Action Steps:

1.Notify RASP regarding modification as soon as the situation is known.

2. As appropriate, consult department chair and Dean regarding requested modification.

3.For projects with co-PI(s), discuss requested modification among project team prior to proceeding to Step 4.

4.Complete and submit Post-Award Modification Request Form.

Once received, a modification request is reviewed by Research and Sponsored Programs. Further information will be collected from the PI, and PI’s department and dean/supervisor, as needed. Research and Sponsored Programs submits the modification request to the funding agency. Once approval is documented, modification specifics will be shared with the Grants Accountant to ensure the University’s official award file remains current.

·         Progress/performance/annual reporting

The PI(s) is responsible for the completion and submission of required reports in a timely manner. On-time reporting is extremely important as funding agencies can withhold payment if project reports are delinquent. Late or unfilled reports can also affect future funding success.

·         Financial Reporting

In coordination with PI(s), the Grants Accountant prepares and sends financial reports/invoices to funding agency/sponsor for reimbursement of expenses incurred. If a narrative explanation of spending is requested by the funding source, the PI is responsible for preparing this information.

·         Close Out Procedure

o   PI submits Final Performance Report to funder and sends a copy to RASP

o   PI & RASP receive Notice of Close Out of Account from Grants Accountant

RASP assists with entering Grant Closeout in RASP database and closing grants in RASP files.