UL Lafayette: ORSP: Policies, Procedures, Forms & Tools: PI Guide: Part VI

Office of Research and Sponsored Programs

UPCOMING DATES:

Guide to Sponsored Program Management for Principal Investigators

ORSP Main > Policies, Procedures, Forms & Tools > PI Guide > Part VI

Part I · Part II · Part III · Part IV · Part V · Part VI · Appendix A

“How is Project Management Different from Just Doing My Research?”—A Quick Guide to Project Management for PIs

A. Progress and Interim Reporting

Most funding agencies require periodic progress and interim reports as conditions of their grants or sponsored agreements. You, as Principal Investigator, are responsible for completing these reports according to the guidelines set forth in the agreement with the sponsoring agency. As explained below, some reports should be submitted directly to the agency and some to ORSP. In either event, they should be submitted at least five days prior to the reporting deadline.

Board of Regents Reporting – Principal Investigators must complete all required reports on the Board of Regents website, http://laregents.org/www2/index.htm. Once you complete the reports, the Board of Regents will notify ORSP. After ORSP reviews and approves the report, it authorizes final submission electronically.

NSF Reporting - NSF requires technical project reports for all assistance awards. PIs should submit annual project reports as indicated below. You must submit electronically via the NSF FastLane system and in accordance with such procedures as NSF may prescribe. In the case of continuing grants, failure to submit timely reports may delay processing of funding increments. Unless otherwise specified in the grant, annual project reports shall be submitted at least three months prior to the end of the current budget period.

Other Reporting – You should submit to ORSP reports other than those for the Board of Regents or NSF. ORSP will review the reports and obtain authorized representative signatures. As PI you are not allowed to sign as an authorized institutional representative or an authorized fiscal/financial representative.

Once any needed corrections have been made and the proper signatures have been obtained, ORSP will submit them to the appropriate agency or individual.

B. Making Post-Award Modifications

You should make post-award modifications if and when you determine that some aspect of the project will need to be changed from what was originally approved by the funding agency or by the university. Funding agencies have widely varying requirements regarding modifications to externally funded grants and projects. Some agencies are flexible, while others require prior approval of all changes.

Certain types of budget revisions require prior funding agency approval on cost reimbursement based grants and contracts. Other revisions that always or frequently require prior funding agency approval include:

Extending or altering project and/or reporting deadlines
Changing the scope of the project
Changing the approved list of equipment to be purchased
Adding or changing subcontractors and vendors
Assigning a new P.I. or other critical project participants
Transferring grants or equipment to or from another institution

You must submit requests for budget and other revisions, including minor revisions to Carl Frantz at ORSP for university approval before sending the request to the sponsoring agency. Revisions submitted to ORSP must be in writing and accompanied by a rationale for the request. If the sponsoring agency requires approval as well, ORSP will then submit the request directly to the sponsor. If you have a good working relationship with the sponsoring agency’s project manager, you may find it helpful to obtain informal approval for a change in advance of the formal request, but this is not required. Donna Fontenot or Carl Frantz in ORSP can answer your questions about post-award modifications.

1. Budget Revisions

You must send to ORSP a request for a budget revision for any change you desire in the budget for your externally funded project. If necessary, ORSP will forward a request for additional approval to the sponsoring agency when the budget needs to be altered beyond the amount or percentage allowed by the agency. Some sponsoring agencies will allow some flexibility (e.g., 10%) between line items, as long as the "bottom line" budget does not change and as long as the line item to which the funds would be moved exists and is already funded. Other sponsoring agencies, including the Board of Regents, generally require their approval for various changes. If you are not sure whether a budget revision is required for your project, contact the Donna Fontenot or Carl Frantz for guidance.

2. No-Cost Extensions

You should request a no-cost extension when you need more time to complete a project than you originally planned. As its name implies, a no-cost extension extends the deadline without adding to the original budget. In most cases the funding agency requires that request for no-cost extensions be submitted 60 to 90 days prior to the end of the contract.

Since it cannot always be assumed that a no-cost extension can or will be granted by the sponsoring agency, PIs and their staffs should do everything possible to complete a project within the originally contracted time frame. No-cost extensions should be requested only when unforeseeable circumstances prevent project completion before the deadline.

No-cost extensions submitted to ORSP must be in writing and accompanied by a rationale for the request. We are here to help you meet sponsoring agency requirements for requesting no-cost extensions, and we also will help you make sure that the new deadline, if approved and granted, is reflected in all university records. Any questions related to no-cost extension can be directed to Donna Fontenot at ORSP.

3. Changes to Approved Equipment

Sometimes the equipment that was originally requested in the proposal needs to be changed. These changes usually occur due to technological advances or changes in product availability or price. When requesting a change to the approved equipment list, send a memo to Carl Frantz at ORSP, including an explanation of the primary technical use of the revised equipment on the project along with the rationale for the change. Again, the Board of Regents is an agency that requires formal approval of changes to equipment approved in their agreements.

4. New or Modified Subcontracts

All subcontracts are subject to the provisions of the university’s prime contract with the funding agency. Please allow sufficient time to create and process subcontracts. Contact Donna Fontentot in ORSP to initiate the drafting a new subcontract or modification to an existing subcontract. You may be asked to provide an explanation of the request, the scope of work, budget, and contact information with the request. ORSP will refer to the Purchasing and Personnel Services Department any proposed subcontract or other contractual agreement for services over $20,000 from a private company or other private entity. These agreements may have to go out for bid and be approved by the state’s Office of Contractual Review. An agreement would not have to go out for bid if you successfully make the case that there is only one source that could reasonably provide the services(s).

5. Changes to Research or Project Scope

If you wish to change the research or project scope or direction, include a detailed explanation of the change, along with the reason why you wish to make the change. ORSP will review and forward your request along with institutional approval to the funding agency.

6. Changes in PI or Other Critical Project Participants

If you are no longer able to act as PI for your project (because your work responsibilities have changed or you are changing institutions, for example), your departmental or other administrative head should make a written request for a new PI to Carl Frantz, Director of ORSP. That administrator should include an explanation of why the PI should be changed and how the new PI is qualified for assuming leadership of the project. The administrator should also attach a C.V. or resume of the proposed new PI, if required by the sponsoring agency. If you need to make a change in other critical staff (such as changing co-PIs), you should also send a memo requesting the same to Carl Frantz, explaining the rationale for the change and including a curriculum vita or resume of the proposed replacement.

7. Transfer of Grants and/or Equipment

PIs who change institutions may wish to transfer their grants or equipment purchased under an externally funded agreement with them. In general, the university will allow the transfer of equipment for federal grants when the equipment is purchased solely by outside sponsor grant funds and it is essential to transfer the equipment to the new university to complete the research project being funded by the grant. You must submit a formal request for the transfer to Carl Frantz for university approval. If UL Lafayette approves the transfer, then ORSP will coordinate funding agency approval through the recipient institution’s sponsored research office

C. Reporting Intellectual Property

The goal of technology transfer at the University of Louisiana at Lafayette is to utilize intellectual property created within the University to stimulate economic development in the Acadiana area and the State of Louisiana and to assist businesses within our community, while enhancing the reputation and impact of the University.

According to the University of Louisiana System Policy on Intellectual Property and Shared Royalties, the creators of intellectual property have a duty to promptly and completely report intellectual property of aSll types; including but not limited to any invention, discovery, trade secret, technology, scientific or technological development and computer software; in which the University has an ownership interest, that has the potential to be brought into practical use for the public benefit, or for which disclosure is required by law.

To disclose intellectual property, simply complete the Intellectual Property Disclosure Form and submit it to the Office of Research and Sponsored Programs. The Intellectual Property Disclosure Form can be found on the ORSP website and in Appendix B of this document.

The University of Louisiana System Policy on Intellectual Property and Shared Royalties applies to all persons employed by UL Lafayette, anyone using institution facilities under the supervision of institution personnel, and undergraduate and graduate students. Note: Disclosure must be made even if the work was done on personal time, or while consulting for a private business or public agency or away from the university campus.

If you have any questions related to intellectual property, contact Ruth Landry, rwl@louisiana.edu, in ORSP (337) 482-5811.

D. Closing Out The Project

1. End of Project Purchases and Restrictions

You should expend all grant funds by the end of the contract. Unless the funding agency specifies differently end-of-grant purchasing requirements or limitations, you should make final purchases with enough lead time to allow the university to pay all final invoices no more than 30 days after the end of the project. This allows the university to make final fiscal and/or purchase reports to funding agencies within the agencies’ deadlines. Many funding agencies require these reports within 30 days of the end of the grant.

You should not buy equipment or materials or make other major purchases near the end of the grant period unless it is specified in the project timeline. Unless it is an equipment grant, federal and state funding agencies generally require that all equipment be purchased and received in time to be used in the project. Equipment purchases made at the very end of the grant period may not be seen as directly benefiting the sponsored project.

If you have any questions about whether an end-of-grant purchase is allowable, please contact either Beth Touchet or Carl Frantz in ORSP.

2. Final Reports

Funding agencies require final reports at the close of the sponsored grant or project. It is critical that final reports be completed accurately and by the funding agencies’ deadlines because:

final reports certify to the funding agency that the purpose of the grant has been met in accordance with the agreement with the funding agency;
final reports certify that the project funds were spent appropriately and in accordance with federal and state regulations as well as funding agency requirements;
many funding agencies withhold final grant payments until final reports have been submitted;
many funding agencies, including most federal and state agencies, may not approve future funding if reports on currently funded grants are late.

Since final reports are official university documents certifying that the requirements of the grant have been met, you must submit them to the ORSP, not directly to the funding agencies. Once submitted, ORSP will ensure that the reports meet funding agency reporting requirements, applicable federal and state regulations, and university policies. Suggested revisions based on this review will then be forwarded to you for action before the final reports are released to the funding agency.

NSF and Board of Regents reports can be completed online by the PI, these reports still require review by ORSP. The review procedure is otherwise the same for electronically submitted reports as for hard copy reports to other agencies. If you have any questions about final reports or the final reporting requirements of a particular funding agency, contact Beth Touchet in ORSP.

3. Record Retention

Federal regulations state that all financial records, supporting documents, statistical records, and all other records pertinent to an award should be retained for a period of three years from the date of submission of the final expenditure report. Following state regulations, the ORSP and Business Services retain all financial and administrative data for five years from the completion of the grant.

As the PI, you are responsible for retention of all technical reports and research data, regardless of the form or the media on which it may be recorded, including computer software. This data is generally defined to include laboratory notebooks or other media such as computer disks and machine printouts and includes both intangible data (e.g., statistics, findings, conclusions) and tangible data (e.g., notebooks, printouts).

You should retain all technical and research data for five years from the acceptance by the sponsoring agency of the final technical report, which is customarily between 90 days and nine months after the end date of your grant. You must provide a copy of such data to ORSP if you leave the institution before the five-year period has elapsed.

4. Restricted Account Closeout

Once an externally sponsored project is completed, all invoices and salaries have been paid, any applicable indirect costs have been recovered, and the final fiscal report sent to the funding agency (along with any excess funds if required as a condition of the grant), then ORSP and Business Services close out the restricted account. This should be completed no later than six months after the award’s end date. In order to help facilitate this, you should:

submit any required final and other reports to ORSP;
make sure that all required receipts and invoices are submitted to Melanie Comeaux in Business Services;
review the monthly expense report as soon as possible after the project is finished and if any errors are found, report them using a Cost Transfer form; and
make sure that all other requests for payment out of the restricted account or companion cost share account, including Direct Charge, Purchase Requisition, and Restricted Account Compensation Request forms are submitted before the end of the grant period.

Taking care of these accounting issues once the grant ends is extremely important, since timely financial reports including final account dispositions are required by almost all funding agencies. If the account is not ready to be closed out by any required time or by six months from the end of the project, whatever comes first, ORSP and the Business Services office will intervene to help close out the account. Unspent funds will be sent back to the funding agency if required as a condition of the grant, or, if not, will be absorbed into the university’s general fund. If the project involving a Center is funded by a fixed price agreement, and appropriate arrangements have been made, unspent funds may also be transferred to the Center’s operating budget.

Document last revised Monday, August 18, 2008 2:34 PM