Post-Award Grant Policies and Procedures
Post-Award Grant Policies and Procedures
Grant awards are made to the institution, not an individual Project Director; therefore, VU assumes full legal responsibility for ensuring that all funds received through the award are used for the purposes and intent outlined in the conditions of the contractual agreement.
Grants and contracts carry administrative responsibilities involving strict accountability. The original grant agreement will be kept in the Grant Specialist’s files. A copy of the grant agreement will be kept by both the Project Manager, and the accounting office. The accounting office will maintain a file for each grant and will begin the proper monitoring of the grant for the entire grant period.
The Project Manager has administrative and reporting responsibilities when managing a grant. It is the Project Manager’s responsibility to be cognizant of all award requirements and contract details, as well as the policies and procedures of VU. It is the duty of the Project Manager to review and oversee the successful completion of the contractual and grant funded activities, as well as prevent financial liabilities for the institution. The Project Manager will be responsible for communicating all programmatic, curricular, and budgetary issues to state and/or Federal auditors.
The Project Manager has the following specific roles in managing a grant:
- Monitor the project budget
- Monitor sub-contractors, sub-recipients, and service providers
- Compiling and addressing any requests from external parties involved in monitoring the grant
- Personnel management
- Property management
- Meet regularly with the Grant and Accounting office
- Manage grant according to all federal regulations and policies
- Maintain progress reports that provide monthly descriptions of performance indicators including outcome measures as well as budget versus actual expenditures and status of all grant activities.
Under the general supervision of the University Controller, an accountant performs a wide variety of pre-award and post-award functions including: assisting with budget development, counseling project managers regarding financial status of grant programs and consulting with and providing assistance to administrators and project managers regarding grant financial oversight to ensure compliance with both federal and non-federal guidelines and institutional policies. The specific controls over compliance with grants must be followed by all Project Managers and can be found at the “Compliance and Controls link”.
In addition to ensuring federal grant compliance, the accountant:
- Prepares timely and accurate invoices for submission to grantors and assures that costs incurred on cost reimbursable agreements are invoiced and paid.
- Communicates effectively with and develops professional, effective working relationships with grant administrators such as federal project officers.
- Works closely with University grant administrators, providing guidance on rules and regulations of sponsored programs to ensure compliance.
- Serves as the primary contact at the University for grant administrators on matters of whether costs are allowable.
- Assists in the implementation of newly issued or revised policies and procedures that affect grant administration.
- Responds to auditor inquiries and provides detailed documentation during audits and reviews of awards.
- Financially manages grants and contracts, including the monitoring and analysis of expenditure levels.
- Manages the grant closeout process, including analyzing and forecasting of data, reporting of data and preparing closeout reports.
- Performs various functions for the month-end close, including creating journal entries, salary adjustments, and reconciliation of accounts.
- Serves as a finance team member by participating in group training and development activities, contributing grants management expertise to the development of the Grant Data Warehouse and it’s reporting.
Time Distribution Reports
Many grants allow staff time to be reimbursed through the grant. All salaries and benefit expenses to a grant should be in accordance with the grant agreement. All employees that charge their efforts to grants will be required to complete at least semi-annual time and effort certification reports. See “VU Time and Effort Reporting Form – Semiannual” for the specific form to use.
Any employee that is charging their efforts to more than one grant funding source MUST complete a bi-weekly time distribution report that reports time by pay period. Refer to “Grant Procedures for Time and Effort Reporting” and “Time and Effort Form links” for further instructions and examples.
All time and effort reports MUST be turned into the designated accountant. The designated accountant will review these reports for accuracy and completeness, and request the necessary allocations of payroll charges based off of these reports.
All Project Managers of grants have been provided with the University’s Cost Accounting Policy (see “VU Cost Policy Statement”). Costs charged to grants that will not be collected from the granting agency for reasons of unallowability, unallocability, or any other reasons must be paid for with University funds.
Technical or narrative reports required by the grantor are to be prepared by the Project Manager, reviewed by either the Program Director or the Grant Office. The Project Manager must maintain all appropriate documentation for the narrative. Project Managers are responsible for obtaining and communicating all due dates for reporting including the final close-out report to the Grant and Accounting Offices.
The Accounting department is responsible for the timely establishment of accounts in the University's financial systems in accordance with the term and conditions of the sponsored agreement. The Director of Accounting is responsible for providing the necessary authorizations and Banner training. The Accounting office also identifies and deposit receipts from sponsors to the proper accounts as well as approves all fund transfers and correcting journal entries.
Grant programs that will receive deposits from both Federal and local sources have separate general ledger account numbers and accounts are coded in the restricted account hierarchy.
Audit and Resolution of Audits
Sponsored projects are subject to agency audit, State audit, and University internal and external audit. All personnel responsible for grants should make their best efforts to save all grant documentation, information, and correspondence in a centralized department file.
The Department managing the grant should have readily available in this central location the following information: grant application, grant contract, procurement files, contracts, progress reports, and other documentation necessary by the grant contract and compliance checklist.
Some granting agencies perform a closeout audit before the grant is administratively closed by the agency. Notify the Grant Office if and when an audit is scheduled for your grant. The Grant Office will work with each grantee to ensure that all audits are resolved.
Sub recipient Monitoring
The Project Manager is responsible for monitoring any sub recipients of grant funds to ensure the organization is in compliance with the grant agreement. The relationship between a sub recipient and the University is similar to a relationship with any vendor or contractor. Employees that are responsible for hiring organizations to perform services or provide goods should always be ensuring that the end product meets expectations. A sub recipient should be held to all of these standards as well.
The exception to the sub recipient relationship is that this monitoring must be documented to be in compliance with grant agreements. All sub recipients must sign an agreement with VU. Each Project Manager needs to work with a designated accountant from the accounting office at the beginning of the grant period to determine the process and procedures that need to be developed with monitoring any sub recipients. A monitoring guide will be developed once this meeting has taken place.
The monitoring guide will state the specific monitoring schedule to follow. The Project Manager is responsible for implementing this monitoring and to report the results to the sub recipient in a timely manner. In addition to performing regular monitoring, the Project Manager must review all invoices submitted by the sub recipient to ensure sufficient supporting documentation and that charges are appropriate, in respect to the outlined objectives and budget in the sub recipient agreement.
The designated accountant will be responsible for monitoring the financial performance of all sub recipients.
The level of monitoring will be determined by completing an annual risk assessment on each sub recipient to the University.
All sub recipients will also be issued an annual letter requesting a copy of the Single Audit report, if applicable.
Financial records, supporting documents, statistical records, and all other records pertinent to an award shall be retained for a period of five years from the date of submission of the final expenditure report or, for awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report. The only exceptions are the following:
- If any litigation, claim, or audit is started before the expiration of the 5-year period, the records shall be retained until all litigation, claims or audit findings involving the records have been resolved and final action taken.
- Records for real property and equipment acquired with Federal funds shall be retained for 5 years after final disposition.
- Indirect cost rate proposals and cost allocation plans are handled in the following manner:
- If submitted for negotiation, then the 5-year retention period for its supporting records starts on the date of such submission.
- If not submitted for negotiation, then the 5-year retention period for the proposal, plan, or other computation and its supporting records starts at the end of the fiscal year (or other accounting period) covered by the proposal, plan, or other computation.
Grant Close Out
All closeout reports required by the granting agency will be reviewed by the designated accountant before submission to the agency. The Project Manager is responsible for reviewing the grant fund at the end of the grant period to determine if there are unspent or overspent funds. The Project Manager will report this information to the designated accountant no later than 90 days after the close of the grant period. Any unspent funds that are requested to be carried forward must have documentation from the granting agency that approves the carry forward.
University Accounting/Procurement Policies/Forms Link:
Contact Information for Post Award Activity:
Conya Wampler, Director of Accounting