This page provides some general tips to principal investigators on important post-award topics.
Prior Approvals (Section 200.407)
Section 200.407 collects all of the references to prior approval. Agencies may choose to implement or waive some, or all, of these, as the Uniform Guidance sets out a broad framework within which federal agencies must operate. In general, agencies differ in their implementation of the Uniform Guidance: consult individual agency guidelines to find out about a particular agency. Most generally important are the need for sponsor approval (if not included in the approved proposal) to:
- Issue an unbudgeted subaward (Section 200.201)
- Use unrecovered indirect costs, including indirect costs on cost sharing or matching as part of cost sharing or matching only with the prior approval of the Federal awarding agency. (Section200.306)
- Use Program Income (Section 200.307)
- Revise budget and program plans, including changes in key personnel or their level of effort (by more than 25%); disengagement of the PI (the new term for absence of PI, to acknowledge that a PI can be absent from campus but still engaged in the project) (200.308)
- Transfer of funds budgeted for participant support costs to other categories of expense. (Section 200.456)
- Incur unbudgeted participant support costs (Section 200.456)
- Purchase capital equipment (cost >$5,000) (Section 200.439)
Internal Prior Approval Form
- Internal Prior Approval Form (IPAF)
The Uniform Guidance includes a number of changes pertaining to subawards with other entities. As a result, a pass-through entity:
- Must make and document a case-by-case determination as to whether the funding recipient should be a subrecipient or a contractor (formerly known as vendor). OSP staff can help with these determinations (Section 200.330)
- Must use an approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal government or, if no such rate exists, either a rate negotiated between the pass-through entity and the subrecipient (in compliance with this part), or a de minimus indirect cost rate of 10% MTDC (Section 200.331)
- Must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include reviewing financial and programmatic reports required by the pass-through entity(Section 200.331)
- Must pay subrecipient’s invoice within 30 calendar days after receipt of the billing, unless the pass through entity reasonably believes the request to be improper (Section 200.305).
- Subaward agreements will be modified to incorporate these changes
Project Closeout and The 90 Day Requirement (Section 200.343)
This is not a new requirement. NSF has always had a strict 90 day close-out policy, but other agencies have been more lenient. However, with the implementation of the Uniform Guidance the requirement will be more stringently enforced. Specifics include:
- The non-Federal entity must submit, no later than 90 calendar days after the end date of the period of performance, all financial, performance, and other reports as required by or the terms and conditions of the Federal award. The Federal awarding agency or pass-through entity may approve extensions when requested by the non-Federal entity (this would be an award end date extension, or no-cost extension, not an extension of the 90 day reporting requirement).
- A non-Federal entity must liquidate all obligations incurred under the Federal award not later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.
- PIs, department and SPRS staff will have to work together to that all project costs are recorded in time to be billed during the 90 day close-out period.
Procurement (Sections 200.318 – 326)
CSU is delaying its implementation until July 1, 2017.