Post-award Grant Handbook
a. Pre-award costs
b. Multiple Grants
c. Tracking Expenses
d. Cost Transfer Policy
e. Allowable and Unallowable Costs
f. Program Income
g. Cost Overruns
h. Changes to Project and/or Budget
i. Communications with Sponsor
j. Award Closeout
a. Federal Funds Payment and Cash Management
b. Personnel Costs
c. Procurement Rules and Thresholds
d. Purchasing Methods
e. Other Types of Expenses
f. Capital Equipment
g. Ownership of Items Purchased with Grant Funds
h. Subcontracts and Sub-recipients
1. AWARD ACCEPTANCE
a. Institutional Review
Funding agencies award institutional grants to Lewis & Clark College on behalf of a Principal Investigator (PI), or Project Director (PD), herein called “PI”. As such, oftentimes the notice of award is sent to an institutional grants office, such as the Sponsored Research Office or the Corporate and Foundation Relations Office. If the award documents are sent directly to a PI, but the funds will be managed by Lewis & Clark, the PI should notify the
appropriate grants office immediately so that the award can be reviewed and accepted in a timely manner.
All institutional awards are made to Lewis & Clark College, not to an individual. As such, institutional review and approval will be required before a grant is accepted. In order for Lewis & Clark to accept an award, specific information must be contained within the award document(s) issued by the sponsor. This includes the:
- Period of Performance: the period from the authorized start date to the authorized end date of a project
- Scope of Work: a narrative description of the work to be completed under the agreement
- Award Amount: the dollar value of the award
- Sponsor Contact and Billing Information: the point of contact, including mailing address, telephone number, and any invoicing procedures.
The appropriate grants office will coordinate formal review of the award terms and conditions, assist with negotiations and publicity, and work with the Business Office to establish a separate, restricted grant account.
Please note that this review and award acceptance process does not apply to awards that are paid directly from the sponsoring agency to an individual (e.g. most fellowships).
b. PI Responsibilities
The PI is ultimately responsible for all aspects of the sponsored project, including programmatic and financial oversight. Primary responsibilities of the PI include Project Management, Expenditure Management, Employee Management, Reporting, and Subaward Management (if applicable). The grants offices and Business Office at Lewis & Clark have established administrative systems and processes to support the PI throughout
the life of an award. Please contact them with any questions or if assistance is needed.
In addition to complying with the terms of the award, it is the responsibility of the PI to meet any applicable requirements. Depending on the funding source and type of award, this may include but is not limited to the following:
- Reporting: The PI is responsible for the timely submission of all reports in accordance with the terms of the grant and requirements of the sponsor. With the PI’s input, the grants office and Business office will prepare any financial reports for submission to the sponsor; a financial report completed by the PI is not an official institutional report of expenditures. The grants office will review progress and narrative reports prior to submission. Copies of all narrative reports and correspondence related to the grant should be forwarded to the grants office.
- Financial Conflict of Interest (FCOI) Training and Disclosure: All PIs and senior personnel working on grants from the National Science Foundation or a Public Health Service (PHS) Agency (including NIH) are required to complete FCOI training and periodic disclosures.
- Code of Ethics: It is the responsibility of all researchers, regardless of the source of funding, to be compliant with the College’s policy.
- Responsible Conduct of Research (RCR) Training: It is the responsibility of all researchers, regardless of the source of funding, to be trained in RCR and compliant with the College’s policy.
- Effort Certification: All personnel who receive any compensation from or have committed effort on a federal grant funded project are required to submit Time and Effort reports.
- Research involving live, vertebrate animals: All work involving live, vertebrate animals must be reviewed by the Institutional Animal Care and Use Committee (IACUC) prior to research initiation.
- Human Subjects Research: All research involving human subjects must be reviewed and approved by the Institutional Review Board (IRB), also known as the Human Subjects Research Committee, prior to research initiation.
- Institutional Biosafety: All activities involving recombinant DNA, synthetic nucleic acid molecules, and/or infectious agents/toxins must be reviewed by the Institutional Biosafety Committee (IBC) prior to initiation. Please note that the College expressly prohibits the use of some organisms, found on Schedule A.
- Dissemination/Publications: Compliance with any applicable public access policy is required, including but not limited to publications resulting from research supported by the National Institutes of Health and/or the National Science Foundation.
- Intellectual Property: It is the responsibility of the PI to comply with the College’s IP policy. A disclosure form is available here. Further, if an invention results from research supported by the federal government, it is the responsibility of the PI to comply with the Bayh-Doyle Act.
- Export Controls: Regardless of the source of funding, it is the responsibility of the PI to comply with Export Controls laws, which regulate 1) the shipment or transfer, by whatever means, of controlled items, software, technology, or services out of the U.S., and 2) the release of certain information to foreign nationals here in the U.S. (referred to as a “Deemed Export”).
- Records Management and Retention: Researchers have certain obligations to record, maintain and retain research records, and to make those records available for grant monitoring and auditing purposes. Research records include research data, materials, documents and information that relate to the administrative, financial, human resource management, reporting of research results, sponsored award applications, cost or pricing, or other management information that has been gathered or used in research activity. The College’s Records Retention Policy is available here.
c. Internal Grant Account Number
Based on information received from the grants office, the Business Office will establish a new account number for each grant, which must be used for all transactions related to the grant budget. The grant account number is made up of 11-digits, and in order for a transaction to be posted to the grant account, the complete 11-digit account number is required. The digits are represented as follows:
- The first three digits will represent the school and the type of account (operating versus restricted). The first digit position represents the school: “1” for a Law account, “2” for a GSEC account, and “3” for a CAS account. The “2” in the second digit position indicates that it is a restricted account; as a restricted account, it may only be used for the purposes defined in the award documents. As such, most external grant accounts begin with 120 (Law), 220 (GSEC), or 320 (CAS).
- The following four digits represent the “department number”, which is unique to each particular grant. The first two digits of the department number represent the program; for example “12” is for federally supported research, “16” represents non-federal external research support, and “32” indicates curriculum development.
- The last four digits represent the expense object code. For example, Lab Supplies are always charged to object 6170 and all salary and benefit charges are made to objects beginning with “5”.
For example, in the case of a federal research grant, the suite of accounts will look something like this:
X20 12XX 4210 Federal Grants: for the receipt of funds
X20 12XX 5101 Non-base other pay (e.g. for faculty stipends)
X20 12XX 5420 Student Labor
X20 12XX 55XX Various benefit accounts
X20 12XX 6170 Lab Supplies
X20 12XX 6220 Equipment
X20 12XX 8600 Administrative Allowance (aka indirect costs)
d. New Award Notification Form
Once the Business Office has set up the restricted grant account, the grants office will generate a New Award Notification Form specific to the grant. This Form will be sent electronically to the PI and any co-investigators at Lewis & Clark, and copied to the Director of Accounting and the departmental Administrative Coordinator, and if applicable the Purchasing Manager, Human Resources, and/or Budget Director. This electronic notification will contain relevant grant information, including the Lewis & Clark grant account number, the agency award number and contact information, the approved budget, and reporting requirements.
e. Advertising an Award
Congratulations! An external grant is great for the PI, the department, Lewis & Clark students, and the College as a whole. This is important information that should be shared with various constituencies if acceptable to the sponsor. When a grant is awarded to Lewis & Clark on behalf of a faculty or staff member, contingent upon the sponsor’s policies, the appropriate grants office will post this information on the L&C website and inform the department chair, the Dean of the College or School, the Business Office, the President, and the Office of Public Affairs & Communication. The Dean may notify other constituencies on and off campus. Occasionally, the Office of Public Affairs & Communication will write a feature article for The Source or The Chronicle, or a press release for wider distribution. All other publications, whether they are grant-supported or not, are great news that the College wants to know about and share!
2. GRANT ADMINISTRATION
The financial management of grant funds is the PI’s responsibility. The authority to sign-off on expenses can be delegated to someone else, but the PI remains responsible for the management of the funds. Please contact the Grant Administrator to authorize another individual to sign-off on expenses. The grants office will meet with the PI to review and plan appropriate financial management of the award.
a. Pre-award Costs
Some funding agencies will allow the College to incur allowable and allocable pre-award costs up to 90 calendar days prior to the award start date. Pre-award expenditures are made at the College’s risk; the funding agency has no obligation to reimburse the College if an award is not subsequently made or is made for a lesser amount than expected. The College may permit the expenditure of funds within this 90 day period only for costs that are absolutely necessary for the start-up of a research project. This mechanism may not be used for the normal expenditure of funds. To request pre-award spending the PI must complete the Grant Change Request Form and submit to the grant office; the form should include an explanation as to why the expenditure is necessary for the effective and economical conduct of the project. Pre-award expenditures must be approved in writing by the Business Office before the PI incurs or obligates the College to incur any pre-award costs.
b. Multiple Grants
Co-mingling of grant funds is expressly prohibited. If a PI is the recipient of more than one grant award, separate restricted accounts will be established for each grant. It is the responsibility of the PI to ensure that expenses and effort are charged to the appropriate grant account and that there is no mixing of funds.
c. Tracking expenses
The grants office will arrange for PI access to view grant expenditures via WebAdvisor. Please note that any credit balance shown in the 4210 object code line represents funds received from the awarding agency. For most federal agencies, the Business Office requests reimbursement of posted expenditures at the end of each calendar quarter. Therefore, the balance shown in WebAdvisor represents the total expenditures posted to the account since the end of the previous quarter, not the amount remaining in the award. In order to determine the award balance remaining, or if any questions arise regarding activity in the grant account, please contact the grants office.
The PI is responsible for budget administration and authorizing expenses to his/her sponsored project award. The PI has the responsibility for verifying that each charge to the award is allowable. On at least a monthly basis the PI is to review account transactions, via WebAdvisor, to ensure expenditures are within the project’s budget, incurred between the project’s start date and expiration date, and identify and resolve potential erroneous postings.
d. Cost Transfer Guidelines
Lewis & Clark’s cost transfer guidelines are designed to ensure that cost transfers meet external regulations, guidelines and terms. Cost transfers may be necessary to correct clerical errors, reallocate effort to reflect actual effort, or to allocate shared services that were previously charged elsewhere. Transfers involving federally sponsored project accounts are monitored, requiring that each request for a cost transfer be justified, documented and completed in a timely manner to support allowability and allocability. It is the responsibility of the PI to review expenditure activity and begin the cost transfer process by contacting the grant office. The grants office and Business Office work closely to ensure all journal entries meet all requirements and are accomplished in a timely manner.
e. Allowable and Unallowable Cost
In accepting a federally-sponsored grant or contract, Lewis & Clark agrees to abide by certain federal rules and regulations regarding the use of the funds. OMB Uniform Guidance sets forth the general criteria that educational institutions must follow in determining whether costs are allowable on federally-funded projects. Many federal agencies also publish additional cost guidelines specific to funds awarded by their agencies, and in certain cases, specific grants or contracts may contain additional allowability guidelines for a particular project. PIs must be familiar with these regulatory requirements in order to appropriately administer federally-funded sponsored projects.
All vendor discounts, credit memos, rebates and other cost adjustments must be applied to the cost of the project.
The following is a companion document to Subpart E of 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. It does not contain the full language of Subpart E. The complete 2 CFR 200 can be found here.
- Allowability - Costs must meet seven general criteria factors to be allowable under Federal awards, as follows: Costs must 1) be necessary and reasonable for the performance of the Federal award, 2) conform to any limitations or exclusions set forth in these principles or the Federal award as to the types or amount of cost items, 3) be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the institution, 4) be accorded consistent treatment, 5) be determined in accordance with generally accepted accounting principles (GAAP), 6) not already be included in a cost sharing or matching requirements of any other externally financed program, and 7) be adequately documented.
- Reasonable - A cost is reasonable if in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity (institution) is predominantly federally-funded.
- Allocable - A cost is allocable to a particular award or other cost objective if the goods or services involved are chargeable or assignable to that award or cost objective in accordance with relative benefits received.
- Consistent - Costs that are consistently treated in the same manner under the like circumstances and are either directly charged or included in Facilities & Administrative Expenses (F&A) recovery, not both.
Unallowable Costs: There are certain activities and costs that the federal government and most private funders deem inappropriate and will not reimburse. These categories of activities and costs are referred to as unallowable. Below is a partial list of activities and costs that are generally considered unallowable under OMB guidelines. 2 CFR Part 200 section Subpart E Cost Principles, includes a Listing of Costs that are Unallowable either as a Direct or Indirect Charge to Federal Grants and Contracts. Unallowable costs include but are not limited to the following:
- Alcoholic Beverages
- Alumni Activities
- Bad Debt
- Commencement and Convocation Costs
- Contingency Provisions
- Costs of Criminal and Civil Proceedings
- Donations and Contributions
- Entertainment Costs
- Fines and Penalties (failure to comply with federal, state or local laws & regulations)
- Fundraising and Investment Costs
- Goods or services for personal use of college employees
- Housing and personal living expenses
- Meals, other than budgeted travel costs
- Student Activities, unless specifically provided for in the sponsored agreement
- Travel: airfare costs in excess of the customary standard commercial airfare (coach or equivalent) are not allowed except under very specific conditions such as the medical needs of the traveler. These conditions must be documented.
f. Program Income
It is the responsibility of the PI to notify the grants office if any income will be generated during the course of a project. Federal Regulations define program income as “gross income earned by a recipient that is directly generated by a sponsored activity or earned as a result of the award.” Program income will be accounted for in specific ways, depending on the sponsor’s policies and any applicable regulations. Regardless of the method used, program income may be used only for allowable costs in accordance with the applicable cost principles and the terms and conditions of the award.
g. Cost Overruns
As the PI, you are responsible for not exceeding the grant budget. If cost overruns occur, they must be corrected during the course of the project. In the absence of other sources of funding that the PI can identify, the respective department budget will be charged for any cost overruns. No additional costs may be incurred before obtaining the appropriate budgetary approvals.
h. Changes to Project and/or Budget
Unforeseeable circumstances may occur that require changes after the award is made. Some of these changes require prior sponsor approval and others do not; please check with the grants office with specific questions. If any changes to the project and/or budget are required, the PI must complete the Grant Change Request Form and submit it to the grants office before making any changes. A written justification of the requested change will be required. The grants office will determine whether your requested changes can be approved internally or if the sponsor’s approval is required. Please allow sufficient time for review and processing.
- No-Cost Extensions: Most sponsoring agencies will allow an extension of the grant expiration date if more time is required to assure adequate completion of the original project scope. If additional time is needed, the PI should contact the grants office in advance of the project expiration date to discuss requesting an extension of the project. Extension requests must be made for programmatic reasons, not financial reasons. Although the requirements to apply for a “no-cost extension” (NCE) vary by sponsor, many federal agencies allow the College to authorize a one-time 12-month NCE for specific reasons, which must be provided in writing. Please be prepared to provide a written technical justification for an extension. Please note that the fact that funds will remain at the expiration of the grant is not, in itself, sufficient justification for an extension. In all cases, such extensions must be requested well in advance of the expiration date. Please complete a Grant Change Request Form and submit it to the grants office as soon as it is known that a grant extension will be necessary.
Mandatory Prior Approvals: Some modifications require approval by the sponsor before any change is made. The specific events requiring prior approval are dependent upon the applicable guidelines and notice of award, but generally the following circumstances require that the PI work through the grants office to obtain prior sponsor approval. This list is not exhaustive.
- Significant Change of Effort by, or Absence of, PI: Under the Uniform Guidance (200.308) prior sponsor approval must be obtained from the federal agency if a PI will be “disengaged” from the project for more than three months, or if there is a 25 percent reduction in the time the PI devotes to the project.
- Participant Support: The transfer of funds budgeted for participant support costs to other categories of expense requires prior approval from the federal sponsor. See 200.308(c)(5).
- Re-budgeting Cost Sharing: Committed cost share must be delivered for the purpose for which is was promised. If any change in the amount or purpose of the promised cost sharing is anticipated, it will be necessary to obtain the prior approval of the federal sponsor before re-budgeting. See 200.308(c)(7).
i. Communications with Sponsor
Communications between Lewis & Clark and the sponsor relative to financial management of projects are to be coordinated through the grants office. This includes, but is not limited to, negotiation of project terms or amounts, budget revisions, interpretation of contract/grant language or any events which may require formal approval of the College or sponsor.
j. Award Closeout
The grant closeout is a critical piece in the life cycle of a grant. Grants are considered closed when all the work has been performed to the granting agency’s satisfaction or upon termination date specified in the award. Preparation for closeout should begin three months prior to the end date of the grant in order to accurately forecast expenses and any adjusting entries that need to be made.
The PI works with the grants office to ensure all project costs are properly identified and compliance has been met with all of the terms and conditions of the award. The PI is responsible for preparing and submitting the final technical report to the sponsor in a timely manner, according to the schedule outlined in the award. The grants office will work together with all departments involved to complete the Grant Closeout Checklist’s three main areas of management; expenses, records, and reporting.
Invention disclosure is critically important for all projects, especially where any portion of the funding comes from the federal government, private foundation, or commercial sponsor. Prompt disclosure is required, although the method of disclosure may vary depending on the sponsor. PIs should work with the grants office to determine exact requirements.
Residual funds or unspent funds on sponsored projects occur when the receipt of revenue or cash from a sponsor exceeds the costs identified and incurred on the project. Since the majority of sponsored projects received by the College are cost reimbursable from a financial accounting perspective, these residual funds on sponsored projects must be returned to the sponsor unless otherwise instructed by the sponsor.
3. FINANCIAL REQUIREMENTS AND PAYMENTS
a. Federal Funds Payment and Cash Management
The purpose of these guidelines are to provide timely and accurate application of remittances for sponsored programs made to Lewis & Clark College. The Business Office manages the cash-related activities, maintaining appropriate cash flow for L&C’s sponsored programs while ensuring financial compliance with Federal regulations, sponsor requirements, and College policies. Lewis & Clark’s Federal Funds Payment and Cash Management Guidelines are available here.
b. Personnel Costs
Personnel are a key element of most grants. Specific personnel and their qualifications may have been identified in the proposal narrative, or the narrative may have described the responsibilities of a grant-funded position to be filled upon receipt of the award. In some cases the personnel are current Lewis & Clark employees whose duties will be expanded or cost-shared and in other cases the personnel are new hires that will be employed by Lewis & Clark and specifically assigned to the grant project. Many grant budgets include funds for PI stipends, hiring students, and/or hiring additional personnel.
- Institutional Base Salary: Lewis & Clark defines Institutional Base Salary (IBS) as “the annual compensation paid by the College for an employee’s appointment. The IBS includes regular salary and may include any additional assignments, such as department chair. The IBS does not include bonuses or one-time payments. The amount of an employee’s IBS shall be described in their appointment letter, and thereafter in annual salary letters or amendments to such letters.”
- Salary Limitation: Lewis & Clark limits supplemental compensation from all sponsored projects to no more than two months of IBS in any one year; this is based on effort expended on a sponsored project outside of the academic appointment.
- Time and Effort reporting: Grant funded employees receiving any compensation from federal grants are required to comply with the College’s Effort Certification policy and processes.
- Payment of Principal Investigator or other grant funded stipends
- The PI should contact the grants office when wages (salary or stipend) are to be paid from a grant budget. With the PI’s input and after verifying allowability and availability of funds for salary, the grants office will initiate this payment by either completing a Personnel Action Form (PAF) or entering a new Activity Pay Assignment into the College’s payroll system, Workday. This includes information such as the account number to which salary will be charged, the amount, the projected effort, and the period over which the salary is to be distributed. If funds are being distributed from a federal grant, this PAF or Activity Pay Assignment will serve as the effort commitment. The request will route for approval to the Dean’s Office (PAF) or electronically through Workday. Prior to submitting the request, the grants office will verify that all required documentation is complete and up to date (e.g. FCOI and/or any applicable training certification).
- In order for the grant salary to be paid at the end of the month, the form must be completed, signed by all parties (grants office, Dean’s Office, Business Office, and Human Resources) and received by Payroll by the 15th of the month.
- Payment schedule: Summer stipends are typically paid over two months in summer - June and July
- Grant Funded Employees
The employment of personnel hired with grant funds is limited to the duration of the grant, or contingent upon continued funding. As hiring supervisor, the PI has the responsibility to select the best-qualified candidate while adhering to all applicable laws and regulations. College staff policies and procedures apply, including but not limited to regular performance reviews. All employees must comply with College policies and processes.
The same hiring process that applies to regular employees at the College is used when hiring grant-funded personnel. In general, the advertising and hiring process involves developing a job description, getting approval, advertising the position, interviewing applicants, and making a selection. For additional guidance please see the Human Resources’ Hiring Resources webpage.
c. Procurement Rules and Thresholds - Purchases made with Federal Funds
The federal government imposes a set of standards for the acquisition of supplies, equipment and real property purchased with federal funds. Procurement procedures must comply with the standards imposed by OMB (Office of Management and Budget) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR-200).
Guidelines for purchases:
- All purchases must be in compliance with the College’s Code of Ethics Policy. In addition no employee, officer, or agent of the College shall participate in the procurement of goods and equipment supported by grant funds (whether federal or private) if a real or apparent conflict of interest would be involved. Such a conflict would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization that employs or is about to employ any of these parties, has a financial or other interest in the firm selected for an award or purchase. The officers, employees, and agents of the college shall neither solicit nor accept gratuities, favors, or anything of monetary value from vendors or contractors.
- The vendor or contractor that meets the required quality standards at the lowest cost should be selected. Recipients should check the procurement website for group purchasing agreements for vendors and contracts that provide discounted pricing. Regardless of the cost of acquisition, grant recipients are required to avoid purchasing unnecessary items.
- Contracts: The General Counsel must review or be involved in the preparation of any contract. The PI should work with the grants office to contact Lewis & Clark’s General Counsel before entering into any contract agreement.
- Capital Equipment is defined by the OMB as “tangible nonexpendable personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit.” The acquisition cost includes installation charges and freight. Additional information is include in section “g” below.
- Debarment and Suspension: No contract shall be made to parties listed on the General Service Administration’s (GSA) list of Parties Excluded from Federal Procurement or Non-Procurement Programs (http://sam.gov). This list contains the names of parties debarred, suspended, or otherwise excluded by agencies, and contractors declared ineligible under statutory or regulatory authority.
- Small, Minority-Owned, and Women’s Business Enterprise Utilization: Colleges and universities expending federal funds are required to make positive efforts to use small businesses, minority-owned firms, and women’s business enterprises whenever possible.
- The Davis-Bacon Act requires contractors and subcontractors on federally funded or assisted contracts to pay their laborers and mechanics employed under the contract no less than the locally prevailing wages and fringe benefits for corresponding work on similar projects in the area. It applies to contracts of more than $2,000 to construct, alter, or repair (including painting and decorating) public buildings or public works. The Department of Labor determines the locally prevailing wage rates.
Purchasing Guidelines based on threshold:
The threshold amounts refer to the total cost of the purchase. For example, purchasing three $900 laptops is considered to be a $2,700 purchase, not three separate items. A $90,000 equipment purchase with a $5,000 delivery/set-up fee and $8,000 in ancillary parts constitutes a purchase over $100,000.
- Purchases under $5,000 (“Micro-purchases”): Purchase order not required but recommended. Competitive quotations not required if the prices are reasonable. Selection based on quality and cost. To the extent practicable, purchases must be distributed equitably among qualified suppliers. The use of a Purchasing Card for such transactions is encouraged.
- All Purchases over $5,000: A Purchasing Card (P-card) may be used if the purchase is under $100,000. If the purchase amount exceeds the P-card limit, the grants office must approve a temporary increase; once approved a temporary increase will be authorized by the Business Office so that the purchase can be made. If the payment will be made by check, a Purchase Order is required. Written price or rate quotations must be obtained from an adequate number of qualified sources (see below). A purchaser should not expend his/her own funds for reimbursement on purchases over $5,000.
Documentation must be maintained that is sufficient to detail procurement history. A quotation is a written statement from a vendor regarding the price for a specific good or service. Quotes and bids should include specifications and qualifying characteristics considered by vendor/contractor including delivery and time frame, scope of work, references, and other relevant specifications.
Procurement and service contract records must contain at least three elements:
- Basis for the vendor/contractor selection. Information showing how the College arrived at the decision to award the contract to that particular vendor/contractor.
- Justification for lack of competition when competitive bids or offers are not obtained. A departure from the “free and open competition” standard imposed by the federal government requires justification. Unique capacity or ability on the part of the contractor (such as specialized research services from a skilled party) is frequently sufficient justification. Nevertheless, because the action represents a departure from normal practice, it is one that is likely to receive close scrutiny in audits or other reviews conducted by awarding agency officials.
- Basis for the award cost or price: the cost and price analysis should be documented to establish that the institution obtained a fair price.
- Any sole source purchase: A Sole Source form must be completed, documenting reason(s) that vendor or contractor is the only source for the item(s) or service(s) being purchased.
- Additional specific requirements as follows:
|Amount of Purchase||Specific Requirements|
|Under $4,999||No competitive cost estimates required.|
|$5,000 to $49,999||Two or more detailed cost estimates, printed from Internet search and/or in writing from vendor|
|$50,000 to $149,999||Three or more written quotations from vendor with specifications clearly delineated|
|$150,000 and more||Three or more sealed bids (formal advertising) or competitive proposals must be solicited from potential vendors/contractors. Must be in compliance with OMB 2 CFR 320.|
If fewer than the required number of estimates/quotes/bides is obtained a Sole Source form must be completed.
The College is eligible for purchasing discounts from specified vendors. See list of group purchasing organizations or contact the Purchasing Manager to determine if a discount might be available.
d. Purchasing Methods
- Purchasing Cards - The most efficient method of making purchases from vendors is to use a College Purchasing Card. To obtain a Purchasing Card (P-card), please read the program details here. Please see Section C above regarding limits and making purchases with a P-card. Before signing off on the P-card expense, be sure that you document why the expense is allocable to the award, both on the back-up documentation and in the Works platform.
- Purchase Order - Purchase Orders are required 1) for purchases over $5,000 if a P-card is not used for payment, or 2) if required by the vendor. A purchase order is created through the requisitioning process before the order is placed. To obtain a Purchase Order, submit a Requisition Form to the grants office. The requisition must include the signature of the PI or designee, the account number(s), an adequate description of goods or services and why they are allocable to the award, and the complete address of the vendor. There must be sufficient documentation that procurement policies have been followed. The College is not obligated to pay an invoice for goods/services that require a purchase order if a requisition is not processed at the time of the order. See table of requirements above.
- Direct Order from a Vendor - Purchases under $5,000 do not require a purchase order unless required by the vendor. When the invoice is received from the vendor, the PI or designee verifies that the goods and/or services have been received. The PI or designated signer then records the account number(s) to be charged for the goods/services on the invoice and signs the invoice authorizing payment. The signer is responsible to verify that the expense is allocable to the grant. The department forwards the invoice to Accounts Payable for payment.
- Reimbursements - Do not pay out-of-pocket for services. The departmental Administrative Coordinator will help complete and submit a request for reimbursement of out-of-pocket material expenditures. There must be sufficient documentation that procurement policies have been followed. See table of requirements above. Making purchases without following procurement policies will put your reimbursement at risk. Further, original itemized receipts are required and the reimbursement request must be submitted to the Business Office within 60 days of incurring the expense. More information is available here.
- Interdepartmental transactions - Goods and services provided on campus may be purchased with grant funds if allocable to the project. Examples include the Mail Room, the Copy Center, Conference and Events and IT Printing Services. Bon Appetit and the Bookstore may in some circumstances be included, although meals, entertainment, and office supplies are very rarely allowable expenses on federal awards. Contact the department providing the goods/services for their ordering and billing procedures.
e. Other Types of Expenses
- Payments to independent contractors for services - An IRS form W-9 is required in order to pay independent contractors. Do not pay out-of-pocket or with a personal credit card for services. You may use a College purchasing card to pay for services. Detailed policy and procedural information is available here. If the individual to be paid is from a foreign country, please contact the Business Office as soon as possible and prior to hiring them to perform any work. US Department of Homeland Security, Department of Labor, and Internal Revenue Service regulations govern the entry, visa status, payment and taxation of these individuals. Lewis & Clark abides by these regulations in all cases. It may take several weeks to complete the paperwork necessary to pay nonresident aliens. More information is available here.
- Travel - Grant funded travel must comply with sponsor and College travel policies and guidelines. When travel costs are to be charged to a grant or sponsored project, the terms stipulated by the funding source will take precedence if they are more restrictive than Lewis & Clark’s policy or guidelines. The Grants Office may provide additional travel guidelines for externally sponsored projects. The departmental Administrative Coordinator may help plan travel and complete Expense Reports. Please note that entertainment expense is not an allowable cost for federal grants.
- Payments to Human Subjects Participants - If funds are required to compensate human subjects for their participation in a research project, the PI can request a “travel” advance. As with standard travel advances, the request will be approved if the PI does not have any advances outstanding more than 60 days after the completion of a trip. In order to clear the advance (which is essentially a loan to the PI) and have the subject payments charged to the grant account, the PI must submit a participant list with the name, date, signature and amount received for each participant, and a summary total. If the names must remain confidential, submit the list as Participant 001, Participant 002, etc. with an initial from each participant.
- Computer Hardware and Software Purchases - Lewis & Clark’s Information Technology Department is able to recommend standard equipment and offers advice on the purchase of computers and computer related products to students, staff and faculty. Before making a purchase of computer hardware or software, please consult with Information Technology to ensure that the specific items you need are currently supported, and that networking is available if applicable. Further, IT can purchase such items included in your grant budget on your behalf, and charge your grant budget directly. Please check out the FAQs of computer purchasing at Lewis & Clark.
- Indirect Cost Recovery - Indirect costs are calculated monthly, by applying the approved indirect cost rate to the applicable expense base. The resulting indirect costs for the month are posted to the grant accounts by journal entry. For reference, Lewis & Clark’s current Cost Rate Agreement with the Department of Health and Human Services, dated December 2, 2014, is 45% of salaries and wages and is effective for the period June 1, 2015 through May 31, 2019.
Any waived indirect cost is considered “cost sharing” and must be approved in advance by the grants office, the Business Office, and the Dean of the College.
f. Capital Equipment
Capital equipment is defined by the OMB as “tangible nonexpendable personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit.” All costs associated with making the asset serviceable can be capitalized. Equipment acquired with external support becomes the property of Lewis & Clark unless restricted by the sponsor.
- PI Responsibilities: PIs are required to ensure the proper receipt of the equipment, track equipment, participate in inventories and notify the Business Office with regard to condition, location, loss or damage to the equipment. The PIs establish maintenance procedures and records and are responsible for the operational condition of the equipment.
- Insurance: Real property and equipment acquired with federal funds will be insured at levels consistent with other Lewis & Clark property and equipment. The Finance Division is responsible for maintaining adequate insurance.
- Record Keeping: Lewis & Clark maintains records including description, serial number, source of funding (including the Federal Award Identification Number, or FAIN), who holds title, percentage of federal participation in the project costs for the Federal award under which the property was acquired, acquisition date and cost, location, use and condition status, and disposition data. This information is maintained by the Director of Accounting as well as stored in the College’s Fixed Asset records.
- Inventory: The Business Office tags assets at the time of acquisition. The Business Office performs a physical inventory of equipment purchased with grant funds every two years to verify existence, condition, and accuracy of records.
- Disposal: If an item purchased with grant funds is determined to be obsolete, and the item’s value exceeds $5,000, disposition rules must be followed. This may include requesting disposition instructions from the awarding agency. Possible disposition practices may require compensating the Federal awarding agency for its proportion of the original cost applied to the fair market value.
g. Ownership of Items Purchased with Grant Funds
Grants are awarded to Lewis & Clark, not to individual PIs. As such, items and equipment purchased with grant funds belong to Lewis & Clark. All institutional policies regarding capital equipment, purchasing, and procurement apply.
h. Subcontracts and Sub-recipients
Federal regulations require that, as a Pass-through Entity (PTE), Lewis & Clark must make case-by-case determinations about whether each agreement in makes for the disbursement of federal funds suggests that the recipient of these funds qualifies as a sub-recipient or contractor.
A sub-award is an agreement with a third-party organization performing a portion of a Lewis & Clark research project or program. The terms of the relationship are influenced by the prime agreement, and all sub-awards must be monitored to ensure that the sub-recipient complies with these terms. A sub-award is more than a handshake between two individuals. When Lewis & Clark receives an award from an external sponsor, the sponsor often indicates the terms and conditions that Lewis & Clark must pass on to any sub-recipient partners involved in the project.
Sponsor approval will be required to have another party perform any part of the funded project if this work was not part of the original proposal to the external sponsor, was not part of the approved award, and/or if the proposed sub-recipient or subcontractor will change for any reason. This process should be initiated by the PI completing a Grant Change Request Form.
Once an agreement with a sub-recipient or contractor has been approved and fully executed, it must be monitored throughout its life. This is the shared responsibility of the PI, the grants office, and the Business Office. Depending on the agreement, responsibilities may include monitoring the activities and performance of entities receiving funding from the PI’s federal award. More information and specific processes are available here.
- Business Office
- Cost Sharing - Cost Sharing or matching means that portion of project or program costs not borne by the Federal Government for federal awards. There are three types of cost sharing to be followed: 1) mandatory cost sharing 2) voluntary committed cost sharing and 3) voluntary uncommitted cost sharing. “Mandatory cost sharing represents the portion of project costs not paid by the sponsor and are required as a condition of the award. Mandatory cost sharing must be tracked and reported. “Voluntary committed cost sharing” represents resources offered on a voluntary basis and specifically included in the award budget. Voluntary committed cost sharing must be tracked and reported. “Voluntary uncommitted cost sharing” refers to any effort or resources contributed to the sponsored project that are not required by the sponsor or included in the award budget. Voluntary uncommitted cost sharing does not need to be tracked or reported.
- Corporate and Foundation Relations (CFR) - Manages L&C relationships with corporate and foundation donors, ensures proper and strategic submission of grant proposals in accordance with institutional priorities, and stewards grants and gifts. Primarily focusing on general projects for research funding for College of Arts & Sciences, as well as all grant opportunities for Graduate School of Education & Counseling.
- Cost Transfer - A cost transfer is an after-the-fact journal entry reallocation of an expense, labor or non-labor costs, after the expense was initially charged to another account.
- Equipment - Tangible nonexpendable personal property with an acquisition cost greater than $5,000 and expected useful life greater than one year.
- Facilities & Administration (F&A) Costs - General business expenses that are not specifically identifiable to a sponsored project, but rather support the project indirectly. These costs are also known as indirect costs. See also Indirect Costs.
- Federal award identification number (FAIN) - The award number or other unique identifying number assigned by the Federal awarding agency, such as the federal grant number.
- Federal Demonstration Partnership (FDP) - The Federal Demonstration Partnership is a cooperative initiative among specified federal agencies and institutional recipients of federal funds. The FDP is a unique forum for individuals from universities and nonprofits to work collaboratively with federal agency officials to improve the national research enterprise.
- Financial Conflict of Interest (FCOI) - A Significant Financial Interest that Lewis & Clark College reasonably determines could directly and significantly affect the design, conduct or reporting of the externally sponsored research.
- Grant Office(s) - The CAS Sponsored Research and the Corporate and Foundation Relations Offices support grant-seeking at Lewis & Clark. For the purposes of this handbook, “Grants Office” can indicate the CAS Sponsored Research Office, the GSEC’s Administrative Services Office, or the Corporate and Foundation Relations Office. See also Sponsored Research Office and Corporate and Foundation Relations.
- Indirect Costs (also known as Facilities & Administrative Expenses) - Costs that are not directly accountable to a specific cost object (including but not limited to a particular project, facility, function or product).
- Institutional Animal Care and Use Committee (IACUC) - Committee ensures animals which are used for research or instructional purposes, their acquisition, care, use, and disposal must be in compliance with current federal, state, and local laws and regulations.
- Institutional Biosafety Committee (IBC) - Oversees research involving recombinant DNA, synthetic nucleic acid molecules, and/or infectious agents/toxins performed, in order to protect the health and safety of employees and the public regarding such research.
- Individual Grant - An award that is issued directly to, and all funds managed by, the individual applicant PI.
- Institutional Grant - The grant is awarded to, and administered by, Lewis & Clark.
- Institutional Review Board (IRB) - A specially constituted review body established or designated to protect the welfare of human subjects recruited to participate in biomedical or behavioral research, also known at L&C as Human Subjects Research Committee.
- No-cost extension (NCE) - Extends the project period beyond the original project end date with no additional funding. May be requested when specified conditions are met.
- Principal Investigator (PI) - The primary individual responsible and accountable for the preparation, proper conduct, and administration of the project or program, including the submission of all required reports. The PI has the appropriate level of authority and responsibility to direct the project or program supported by the grant and is responsible for leading and directing the project, intellectually and logistically.
- Project Director (PD) - A project’s point person, managing resources and overseeing finances to ensure that the project progresses on time and on budget. Sometimes used interchangeably with Principal Investigator.
- Responsible Conduct of Research (RCR) - The highest standards of excellence and integrity in all research and scholarly endeavors. Lewis & Clark College RCR policy available here.
- Senior Personnel - The PI and any other person identified by the PI, in the grant application, progress report, or any other report submitted to the funding agency by the College as independently responsible for the design, conduct, or reporting of the research. All of the following may be considered Senior/Key Personnel, to the extent they are independently responsible for the design, conduct or reporting of the research: professorial faculty, research associates, emeritus faculty, sub-recipient personnel, postdoctoral research associates, research collaborators, visiting scientists, individuals with courtesy appointments, as well undergraduate, graduate and post-doctoral students. The term does not commonly apply to departmental research administrators or research administrative professionals.
- Sponsored Research Office (SRO) - Provides faculty and staff in the College of Arts & Sciences with professional and quality support in the acquisition and administration of external funds, including federal, for research, and creative endeavors.
- Subcontract - A formal agreement between L&C and another organization by which responsibility to perform a sizable portion of the work is transferred from L&C to a third party.
- Sub-recipient - A non-federal entity that receives a sub-award from L&C to carry out a portion of the project work as specified in the proposal. The sub-recipient will participate in decision making and in determining the direction of the project, and will participate in and contribute to the final products and/ or report.
- Time and Effort Reporting - Certification of effort to document salaries charged to federally sponsored project.
5. POST-AWARD FORMS
All forms can be downloaded at the Sponsored Research Office’s form downloads page.
- Financial Interests Disclosure Form
- Grant Change Request Form
- Grant Closeout Checklist
- Invention Disclosure Form
- Time and Effort Reporting form for Students