Critical Administrative Compliance Areas
The following list is not meant to be exhaustive, but highlights some of the key areas administrators should manage and monitor to ensure compliant administration of sponsored awards. Educational institutions follow the principles described in the OMB Uniform Guidance, Cost Principles for Educational Institutions, as their guide for determining costs applicable to grants, contracts and other agreements. VCU also provides detailed guidance in the Post Award Financial Administration Policies for direct and indirect costs.
Good questions to ask when determining if an expense should be directly charged to a project would include:
- Is the expense allowable under OMB Uniform Guidance principles and sponsor terms and conditions?
- Was the expense part of the approved budget?
- Is the expense clearly identifiable as necessary for the conduct of the project?
- Is the expense consistently treated as a direct cost by your institution?
Administrative costs such as clerical or administrator salaries, general office supplies, computer supplies, basic telephone, and memberships and subscriptions generally should not be directly charged to a sponsored project. These items are most often treated as indirect costs and are included in the calculations used to negotiate an institution's finance and administration rate agreement. Some projects, however, require a heightened amount of administrative attention/support where direct charging administrative costs may be reasonable and allowable. It is important that any administrative costs direct charged to a project are clearly proposed and approved in the award. Examples of why direct charging administrative salaries may be appropriate can be found in VCU's Post Award Financial Administration Policies, Treatment of Administrative and Clerical Costs.
Effort reporting is required under OMB Circular A-21. Effort reporting is done retrospectively as a means to ensure salary charged to a sponsored project reasonably reflects the level of work performed. The best way to ensure effort reports are accurate is to proactively manage labor assigned to a project by having open communication lines between the PI, other project staff and administrators, as well as conducting a monthly reconciliation of expenses to include PI-level review.
Having an audit finding of non-compliance in effort reporting can place an institution and the individual certifier at significant risk and could result in loss of sponsored funding, large fines and damage to reputation. Key areas of risk include:
- Individuals certifying effort that do not understand the requirements
- Individuals certifying effort of those that they do not have first-hand knowledge of actual work performed
- Late certifications
- Actual effort performed is not accurately reflected by salary charged
- Certifying to budgeted effort, not actual effort performed
- Certifying 100 percent time toward sponsored projects and not charging non-sponsored activities to university sources (e.g., time spent writing new grant proposals)
Department administrators are responsible for ensuring compliance with any salary limitation imposed by a sponsor. When an award or agency has a salary cap restriction, such as the NIH salary cap, it is expected the department of the faculty member who is over the salary cap will provide the appropriate amount of cost share salary in accordance with committed effort on the project and the amount of salary that is above the salary cap.
Institutions that do not comply with salary caps are at risk for loss of sponsored funding, large fines and damage to their reputation. Key areas of risk include:
- Direct charging salary above the cap to the restricted project
- Calculating the amount to be cost shared incorrectly
- Failure to properly document salary cap cost share
- Failure to update cost share allocations when salary changes or the salary cap changes
Department administrators are responsible for working with investigators to identify erroneous charges on projects during the monthly reconciliation process and make any necessary cost transfers within 60 days of the charge appearing on a monthly expense report. See Grants and Contracts Accounting's cost transfer procedures for more detail.
Appropriate documentation and justification to support cost transfers must always be maintained at the department level. It is essential to make any necessary cost transfer as soon as possible after the error is discovered. Auditors pay increased attention to cost transfers occurring on sponsored projects that: (1) are more than three months after the actual cost was incurred, (2) are during the final month of the budget period (see accelerated spending) and (3) occur after the budget period has expired.
Departments should create advance indexes when they have received unofficial notice that a project will be awarded or the agreement is in negotiation. If work on a project has begun and expenses are incurred, requesting an advance index will ensure all project expenses are accounted for appropriately and avoid the risk of untimely cost transfers.
Increased spending of funds toward the end of a project or after the budget period end date is an area where auditors commonly focus attention. It is imperative spending on a project is allowable and considered reasonable and necessary to complete the objectives of the project. Purchasing items such as equipment, computers and large amounts of supplies on a project that is near its end date are red flags for auditors to more closely scrutinize the expenses and question the direct benefit the expenses would have on the project.
Unacceptable justifications for accelerated spending on a project include:
- To spend down the unallocated budget,
- Because another project ended or
- To offset cost-overruns on another sponsored project.
PI Roles and Responsibilities
Please contact your department research administrator if you have specific questions about your monthly expense report.
If you have any questions about the PI Dashboard or the monthly review certification process itself, please contact SOMRESADMIN@vcu.edu.
Key pre-award responsibilities of the principal investigator (PI) include:
- Notify department of intent to submit a proposal well in advance of the sponsor's published deadline. Allow ample time for proposal development and delivery to SOM Dean's Office for school-level review prior to Office of Sponsored Programs review.
- Develop technical content of the proposal and provide information to department to aid in translating the technical needs of the project into a budget.
- Identify key personnel and their level of involvement.
- Inform department of any subcontracts or subawards and assist in collecting required proposal documents from subawardees.
- Complete and keep updated Conflict of Interest disclosure statement in the AIRS system.
- Ensure the following upon submitting proposal to SOM dean's office for school-level review:
- The RAMS-SPOT Funding Proposal is complete.
- PI has coordinated financial conflict of interest reporting by all designated COI investigators.
- PI has completed any required training for system submission and/or requested user ID if required by sponsor.
- A signed subrecipient commitment form or letter has been completed and is uploaded to RAMS-SPOT for all proposed subawardees.
- Internal subaccounts have been indicated in RAMS-SPOT as applicable/agreed upon by participating departments and schools.
- The proposal has been prepared in accordance with sponsor application terms and conditions as well as sponsoring agencies rules and regulations.
- The entire proposal meets the administrative requirements outlined in the application instructions.
- A current, fully executed MOU exists for faculty members conducting sponsored research that have a joint appointment with a veteran’s affairs medical center. See SOM Guidance for Joint Appointment MOUs. Investigators and administrators are encouraged to utilize the VA MOU Template.
The principal investigator (PI) has primary responsibility for technical execution of the project and compliance with both the institution and the sponsor's financial and administrative policies, and regulations associated with the management of the award. PIs typically rely on administrative staff to assist them with the day-to-day management of project funds; however, the primary responsibility for the management of the sponsored research award rests with the PI.
Key post-award responsibilities of the principal investigator include:
- Executing the project as approved in the sponsor award, directing all project staff activities and ensuring adherence to VCU's policy on the Responsible Conduct in Research and Scholarship.
- Ensuring all appropriate regulatory approvals are current, accurately reflect the work performed and are on file with the IRB or IACUC, as applicable.
- Work with department administration to ensure the project's financial expenditures are in line with the approved funded proposal budget and reflect the work performed. Request prior approval for budget changes according to institutional and sponsor policies and procedures (see “PI role in monthly reconciliation of expenses” section below).
- Report project progress to the sponsor as outlined in the terms of the award.
- Maintain both project technical and administrative/financial records including data, lab notebooks and an accurate record of project-related expenses.
- Communicate regularly with project technical staff on project progress and changes in duties assigned as applicable.
- Communicate regularly with department administration to ensure expense allocations and personnel assignments for a project are accurate. Provide justification for changes when necessary.
- Comply with all applicable sponsor rules, regulations and/or terms and conditions of the award.
Please refer to VCU's Office of Sponsored Programs' Roles and Responsibility Matrix for a comprehensive list of PI responsibilities as well as the responsibilities of support staff, department administration and institutional offices as it pertains to the compliant administration and execution of an award.
PI role in monthly reconciliation of expenses
VCU institutional policy requires that all financial accounts be reconciled on a monthly basis. The reconciliation process includes the review of expenses incurred to ensure they are appropriate as well as reviewing source documentation for the charges and maintaining a file of those records. For non-sponsored accounts this duty is typically performed by administrative staff.
For Sponsored Programs, the responsibility for reconciliation rests with both administrative staff and the PI. PIs are expected to review monthly expense reports to ensure the expenses incurred are appropriate for the project. PIs should work with department administration to request and review back-up documentation for expenses requiring additional review. If erroneous charges are found, PIs should work with department administrators to document the corrective action needed to fix the errors.
VCU has instituted an electronic process for PI's to certify they have reviewed their monthly expense reports for all active sponsored accounts. PI's will receive an email each month directing them to the PI Dashboard to review the expenses on their sponsored accounts for the previous month.
Instructions for viewing and certifying review of monthly expense reports:
- Once you are logged in to the VCU Reporting Center, navigate to the PI Dashboard tab at the top of the page.
- In the Alerts and Notifications portlet, click on the link "Reports Available for Review."
- Click on "View Report" to download the "Monthly Expense Report" for each award index.
- After you have reviewed the report, click on "Certify Review."
Policy and Guidance Documents
Would you like that in writing?
Our office has developed Standard Operating Procedures and other guidance documents that touch on all aspects of sponsored activity in the School of Medicine: from activating and managing clinical research to grant proposal submissions, from administering active awards to support services for our centers and institutes.
Joint VA Appointments
Requirements for Faculty with Joint VCU/VAMC Appointments and Externally Funded Research
VCU Faculty who hold paid appointments at VCU and also have a paid appointment at a Veterans Affairs Medical Center (VAMC) are considered to be faculty holding a joint VCU/VAMC appointment. This relationship is quite common between academic medical centers and VAMCs.
The federal government requires that Faculty Investigators who hold joint university and VAMC appointments define their total professional responsibility between the two institutions by disclosing and documenting their time spent on research and other activities at both institutions no less than annually. This disclosure is done through a Memorandum of Understanding (MOU) approved by appropriate individuals at both the university and VAMC.
The VCU School of Medicine has developed guidance and an MOU template to aid investigators and their department administration in ensuring the MOU is completed and approved no less than annually
Frequently Asked Questions Regarding Joint VA Appointments
The MOU is required in order to clearly document how much total professional effort of a faculty member is available for research for both the university and VAMC appointments. The MOU further certifies that there is no possibility of dual compensation [payment by more than one entity for the same effort] for the same work or of an actual or apparent conflict of interest.
The NIH defines total professional effort as the total (100 percent) professional responsibilities of an investigator for their efforts at both the university and VAMC. University effort is 100 percent of the activity funded under the VCU institutional base salary. The institutional base salary is the total of VCU and MCVP salary as applicable. The percent effort proposed in a university grant application is the percent of university effort. A conversion must be made when translating the university committed effort to total professional effort for joint appointment MOU reporting purposes.
VA appointments are often referred to as a VA Tour of Duty and are categorized in eighths and based on a 40 hour work week. Each VA eighth represents 5 hours. Example - A 5/8 VA appointment is equivalent to a 25 hour work week ((5/8)*40)=25.
No. The salary used for VCU proposal submissions is an investigator’s institutional base salary. This is the total of the VCU and MCVP salaries as applicable. The NIH sets guidelines in determining institutional base salaries. Since salary earned from a VAMC is paid through a separate, federally-funded paycheck, this compensation is not included in the VCU institutional base salary.
The salary used for university proposal submissions (institutional base salary) is the compensation used for the purpose of determining whether an investigator is over the NIH salary cap.
Yes. Any faculty member holding a joint VCU/VAMC appointment should disclose the joint appointment in the budget justification of an application for funding.
Yes. Sponsors are expecting disclosure of all research, regardless of funding. Investigators should be certain to clarify when representing effort on Other Support pages to clearly indicate whether they are using total professional effort or the university effort only.
No. The VCU effort report is a reflection of the work performed under your VCU institutional base salary. This is the total of the VCU and MCVP salaries as applicable. Only university effort is reported on VCU effort reports.
The university has put in place several required trainings, both online and in person, that are a part of the PI’s responsibilities in conducting sponsored research at VCU. Some of these trainings are mandated at the federal level, while others are specific to sponsored research administration at the university
More School of Medicine-led research administration training sessions are coming soon! Check back for more information.
Office of Sponsored Programs Training
- Mandatory Training for PIs and Research Administrative Staff
- Use the Mandatory Sponsored Project and Effort Reporting Training Get Started Guide to assist with locating and self enrolling in the Blackboard training course in addition to confirming completion.
- Getting Started in Research Administration Guide
Grant and Contracts Accounting Training
- Banner Post Award Basics Guide
- Overview of Post Award Management
- Cost Transfer Work Flow Diagram
- Cost Transfer FAQs