Post Award Procedures
Revised January 15, 2013
Table of Contents
.010 General Information
.045 Invoices to Sponsors
.050 Direct Costs
.060 Indirect Costs
.090 Expenditure Reports
.130 Invention Reports
.140 Technical Reports
.150 Close Out Procedures
.160 Record Retention
In accordance with Kansas Statutes Annotated (K.S.A.) 76-721, 76-724, and 76-725, the Chief Executive Officer of Kansas State University (KSU), or whomever he so delegates his authority, may apply for, accept, and receive any "agreements" such as contracts, private donations, gifts, grants, or bequests from any agency of the U.S., any state, any subdivision of any state, and any person, partnership or corporation, if the purpose is related to the operation or function of KSU. These "agreements" are legal documents which bind the parties to the terms stated in the document.
After an "agreement" is received by KSU, the Division of Financial Services, Sponsored Programs section is responsible for ensuring that post award procedures and guidelines specified within each "agreement" are followed. Adequate files and records must be maintained for each "agreement". The official university files are maintained in the Division of Financial Services, with copies filed by the departments involved. Each of the documents filed with Sponsored Programs to bear the original autographed signature of the authorized officials for the parties, if the document provides for signatures.
The official university accounting records are maintained in FIS. FIS statements should be the source used for preparation of financial reports or information for sponsors or other entities.
Once an agreement has been received by KSU, Division of Financial Services, Sponsored Programs staff will assign the FIS Project Number(s), Organization number, Source, and Award Number(s) for all sponsored agreements and enter the necessary information in FIS to establish the account(s). More information about Organization numbers, Sources, and Department alphas may be found on the Division of Financial Services website under Systems, Chart of Account Information.
1. Project Number ("G" number)
Sponsored Programs staff may assign multiple project numbers assigned to an agreement depending on the specific circumstances of the agreement. Departments may also request that Sponsored Programs establish multiple project numbers for an agreement.
Each subaward under an agreement will be assigned a separate project number.
Project Numbers for sponsored agreements are 10-digit numbers with the format GXXX123456.
G= used for all sponsored agreements
XXX = department alpha
123456 = unique number
If the project number is for a KSU subaward to another entity, the six-digits will be alpha-numeric, with two alphas and four numeric. The alphas will assist in identifying the recipient of the subaward. The four numeric characters will correspond to the numeric portion of the related Award Number (described below).
2. Organization (Org)
A five-digit organization number is assigned to each sponsored agreement Project Number to correspond with the three-digit department alpha contained in the Project Number.
A Source is assigned to each sponsored agreement to correspond with the type of funding being provided (for example, 3145 is the source for Main Campus Federal funds).
4. Award Number
Each agreement is assigned a six-digit Award Number with the format: XX1234.
XX = corresponds to alpha abbreviation for categories of sponsors used by Sponsored Programs for invoicing processes.
1234 = unique number
5. Matching Project Numbers ("M" number)
When non-salary expenditures are promised in the agreement as a matching commitment, a Project Number to be used for these expenditures will be assigned by Sponsored Programs. This project number will use the same department alpha and unique six-digit numeric that is assigned as the sponsored agreement Project Number (described above), but will begin with the letter "M" in place of the letter "G". Organization and Source are not assigned to these project numbers. These are determined by the funds the department chooses to transfer to the "M" project number. Funds from multiple sources and organizations may be transferred to one "M" Project Number, however expenditures must be charged accordingly.
Line item budgets are established in FIS in accordance with the terms of the agreement or subsequent approved revisions. The line item for Indirect Cost is not available to departments for expenditures. Indirect costs are automatically charged to the account each month-end based on the expenditures incurred and the indirect cost rate specified in the sponsored agreement.
All deposits to sponsored agreement project numbers (all projects beginning with "G"), including checks from sponsors, refunds from vendors and receipts via an Interfund Voucher (IFV) must be completed by the Sponsor Programs. Departments cannot deposit funds to sponsored agreements.
1. Checks (or cash) from sponsors or vendors
Checks or cash received by departments from sponsors or vendors should be submitted to Sponsored Programs with account number information noted, if known.
2. Receiving side of an Interfund Voucher (IFV)
Please contact the Sponsored Programs for assistance in completing the receiving side of an IFV. In most cases a "generic" project number must be used in place of the "G" project number or the document will not process in FIS. A transfer of funds from the generic project to the appropriate "G" project via Accounts Receivable in FIS must be done by Sponsored Programs to complete the deposit.
A majority of sponsored agreements include terms and conditions for receipt of payment that require the university to extend credit to the sponsor. In other words, university departments must incur costs and the sponsor must be invoiced before payments are received. Sponsored Programs prepares and submits invoices to sponsors for all sponsored agreements in accordance with the terms and conditions specified in the sponsored agreement. For certain federal agencies, Sponsored Programs will request funds electronically. Other federal or non-federal sponsors may require invoicing on a monthly, quarterly or other basis, while some sponsors may pay in advance or make scheduled payments. Full compliance with the terms and conditions for invoicing significantly increases KSU's ability to collect all amounts due from sponsors. Accordingly, departments must submit charges to accounts on a timely basis and provide all required documentation to Sponsored Programs within designated deadlines.
In the event that a sponsor does not make all payments as promised in the agreement, all unreimbursed costs become the responsibility of the department that incurred the expenses while conducting the sponsored project. Certain sponsors present a higher risk for non-payment than others. Typically, industry and private sponsors present the highest risk, while awards directly from federal agencies, state agencies or through other universities present a lower risk. Departments should consider these risks when conducting projects with the various types of sponsors and exercise due diligence to deploy proactive measures to help mitigate the level of risk to which the department may be exposed. In addition to a contingency plan for funding unreimbursed costs, due diligence measures should include regular communications between departmental administrators, principal investigators, and sponsors to insure that the sponsor/university relationship is being managed in a proactive manner to avoid misunderstandings, to insure that each party is fulfilling their contractual obligations and to determine developing circumstances that could potentially lead to a dispute with the sponsor.
Sponsors may choose to remit the funds to KSU by check, wire/ACH, or by interfund voucher when the sponsor is a State of Kansas agency. All funds should be remitted to Sponsored Programs for deposit. (See section .040 of this chapter for deposit procedures).
Sponsored Programs, on behalf of the department/unit, will assume a lead role in the collection of amounts due to department's sponsored project accounts from sponsors (accounts receivable) using the procedures described here.
The first overdue notice will be sent to the sponsor at 90 days past the invoice date (or payment due date for scheduled payments). The department will receive a copy of the notification and should promptly notify Sponsored Programs of any information they have regarding the reason for non- payment (for example, an overdue technical report).
Normally, as a minimum attempt to facilitate payment, up to three overdue notices will be sent by Sponsored Programs during the first 90 days of delinquency. The department and Principal Investigator will receive copies of subsequent notices to the sponsor or other related correspondence.
If payment is not received within 180 days past the invoice/due date, the account will be reviewed by Sponsored Programs and may be declared uncollectible at this time. Certain factors, such as the type of sponsor, sponsor's payment history, or other information from the principal investigator or sponsor will be considered prior to declaring an account uncollectible.
Once an account is determined to be uncollectible, the department will be notified by Sponsored Programs in writing. The department will be required to take one or more of the following actions for resolution of the bad debt.
In the event that there is a dispute with the sponsor over contractual terms or results of the work, the department should seek assistance from the Office of Research and PreAward Services, or the Office of General Counsel to attempt to resolve the issue. Sponsored Programs must be notified in writing of such action and should be provided with a time estimate for resolution of the bad debt.
Provide the Division of Financial Services with written authorization to refer the account to a collection agency and State of Kansas set-off. An FEIN or other tax ID number for the sponsor will need to be provided. If the collection agency cannot collect the funds due within six months, the Division of Financial Services will recall the account from the collection agency. PPM Chapter 6210 provides additional details regarding collection through a collection agency.
Submit a written plan to the Division of Financial Services for repayment of unreimbursed costs from departmental funds. In the event that the amount to be repaid is substantial, a department may be allowed to submit a plan that spreads repayment across more than one fiscal year. The department must submit such a plan if the other noted options are not applicable or are not attempted or do not result in full payment of the amount due. In the event that a plan is not submitted as required, Sponsored Programs will transfer the costs to a departmental SRO account or other unrestricted account. Documentation of the transfer will be provided to the department.
The Federal Office of Management and Budget (OMB) Circular A-21, Section D.1., states that "Direct costs are those costs that can be identified specifically with a particular sponsored project, an instructional activity, or any other institutional activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances must be treated consistently as either direct or indirect costs. Where an institution treats a particular type of cost as a direct cost of sponsored agreements, all costs incurred for the same purpose in like circumstances shall be treated as direct costs of all activities of the institution." Examples of such costs, but not limited to, are salaries and fringe benefits, supplies, travel, and equipment.
OMB Circular A-21, Section J.8., requires that payroll charges to Federally sponsored projects be supported with adequate documentation. KSU uses the Personnel Activity Reports (PAR) for this purpose as explained in Section 7000, PPM Chapter 7070.
OMB Circular A-21, Section E.1., states that "Indirect costs are those that are incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular sponsored project, an instructional activity, or any other institutional activity." Examples of such costs, but not limited to, are depreciation, administration expenses, operation and maintenance expenses, and library expenses. For the latest federally approved Modified Total Direct Cost (MTDC) rates, see Section 7000, PPM Chapter 7010.
Indirect costs are automatically charged monthly to each applicable sponsored project account at the rate determined in the "agreement". In addition, the indirect costs are automatically distributed monthly to the appropriate department accounts based on KSU administrative policies.
Should it be necessary to ask for non-university assistance to fulfill a sponsored project, and the proposal budget or subsequent "agreement budget" names a sole-source consultant/other professional service (the only institution/person who can do the job), and if the amount is to exceed $5,000, a formal consultant/other professional service agreement must be processed through KSU PreAward Services after obtaining sole source approval from the KSU Purchasing Office. See Section 6300, PPM Chapter 6310 for special purchasing procedures for sponsored research projects for sole source, Section 7000, PPM Chapter 7010 for proposal budget preparation procedures, and Section 10,000, Filing No. 10,107, pg 2 of 11, of the Division of Accounts and Reports Policy and Procedures Manual for state procedures.
The $5,000 limit is applicable to the overall contract commitment with a particular consultant or other professional, regardless of the number of sponsored agreements or other projects involved. Departments must consider all payments that will be made to the consultant or other professional, including travel reimbursements and payments over multiple fiscal years and/or from multiple projects when considering the dollar thresholds. Example: A three-year agreement (even if each year is budgeted in a separate award or project) at a cost of $2,000 per year is a $6,000 contract and purchasing approval is required.
If the proposal budget or subsequent "agreement" budget does not indicate the consultant/other professional service provider, and if the amount is to exceed $5,000, bids must be taken and files maintained of the bids received or specific sole-source approval must be received from the sponsor. See Section 6300, PPM Chapter 6310 for special purchasing procedures for sponsored research projects for competitive bidding. Once approved, a formal agreement must be processed through KSU PreAwards Services. After the agreement has been processed through KSU PreAward Services, Sponsored Programs will send a copy of the fully signed agreement to the department.
Should it be necessary to ask for non-university assistance to fulfill a sponsored project, and the proposal budget or subsequent "agreement budget" names a subawardee (entity completing a significant part of the research or substantive effort), a formal subaward agreement must be processed through KSU PreAward Services. See PPM Chapter 7010 for proposal budget preparation procedures, and Section 10,000, Filing No. 10,107, pg 2 of 11, of the Division of Accounts and Reports Policy and Procedures Manual for state procedures.
If the proposal budget or subsequent "agreement" budget does not indicate the subrecipient, contact PreAward Services for guidance on a revised budget. Once approved, a formal agreement must be processed through PreAwards Services.After the agreement has been processed through KSU PreAward Services, Sponsored Programs will send a copy of the fully signed agreement to the department.A letter will be sent to the subrecipient if/when annual equipment, invention and/or MBE/WBE reports are due. In addition, a letter will be sent to the subrecipient requesting final financial reports, the final invoice and a request for the required A-133 documentation when it becomes available. Additional requests for A-133 documentation are sent on an annual basis.
After an agreement has been signed by KSU, revisions may be necessary. All revision requests to sponsors are handled by PreAward Services in the same manner as the original proposal. See Section 7000, PPM Chapter 7010. Post-award staff are available to advise what budget revisions are needed.
Expenditure reports are required for some sponsored projects. The KSU Division of Financial Services, Sponsored Programs section sends a notification to the department when an expenditure report is needed and encloses the required forms if available.
The department is to prepare the expenditure report in accordance with the instructions in the notification and/or sponsor's manual. The expenditure limitation as set forth on the line items in the notification letter and/or award notice must be observed. Items received after the end of the project period are not allowable on awards that require accountability and/or audits. However, items received prior to the end of the project period, but not paid until after the end of the project period that are allowable, should be listed on an outstanding list and attached to the final report. See Section 7000, PPM PPM Chapter 7050, .300 - Sample Form - Outstanding Obligations for format). Outstanding items are those items that are not recorded as an expenditure under the project year column of the FRS FBM 090 account statement as of the end of the project period. PLEASE NOTE THAT OUTSTANDING PAYROLL COSTS MUST SPECIFY THE FOLLOWING:
NAME OF THE PERSON
SOCIAL SECURITY NUMBER
Also note that the Office of Management and Budget has revised Circular A-110 to say: "Unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions."
Cost sharing or matching costs, if required, are to be reported and submitted with/on each expenditure report. The amount for salaries used for cost sharing are to be taken from the Cost Sharing for Sponsored Project Reports, which are prepared from the Personnel Activity Reports and mailed to the department approximately three weeks after the end of the last payroll period in a semester. (See Section 7000, PPM Chapter 7070 for more information about Personnel Activity Reports). The amounts other than salaries used for matching should be taken from the matching account statement for the period covered by the report. BEWARE: Funds in matching accounts in state general funds lapse at the end of each fiscal year. Therefore, these monies must be spent or encumbered by the end of each state fiscal year. Funds in SRO accounts do not lapse, however they must be encumbered. See OMB Circular A-110 Section __ .23 for federal cost sharing or matching requirements.
The Principal Investigator and the Department Head are to sign or initial the expenditure report as instructed in the notification letter. The required number of completed copies, per the notification letter, and the list of outstanding obligations are to be forwarded to KSU Division of Financial Services, Sponsored Programs.
Sponsored Programs will review the expenditure report (including overhead and cost sharing or matching costs, if applicable) and sign as the Financial Officer. Sponsored Programs will forward the required number of copies to the sponsor, retain one copy for the official University files, and return any remaining copies to the department.
.100 Special Financial Reports
Some sponsors do not require separate final financial reports, however the university must report the final total expenditures to the sponsor. Currently National Science Foundation, U.S. Department of Education and some U.S. Department of Agriculture awards require a summary report from the University. In order to do so, the KSU Division of Financial Services, Sponsored Programs section forwards an "Outstanding Obligations" form to the appropriate department head when one of these awards ends. The forms are to be completed and returned within 90 days, showing all obligations which have not been recorded as paid on the Division of Financial Services account statement as of the ending date of the award. Note that "unless the Federal awarding agency authorizes an extension, a recipient shall liquidate all obligations incurred under the award not later than 90 calendar days after the funding period or the date of completion as specified in the terms and conditions of the award or in agency implementing instructions."
.110 Disposition of Federal Property Including Transfers
The department shall complete a Disposition of Property form DA-110 per the instructions and routing procedures in PPM Chapter 6510. List only those items coded federal per Section 6500, PPM Chapter 6510, on the same DA-110. Do not list items requiring this special approval on the same DA-110 form with non-federal items. Include the KSU account number the equipment was purchased from in the description of the property. The KSU Division of Financial Services, Financial Reporting and Asset Management section will screen the DA-110's that involve federal property and route them through the KSU Division of Financial Services, Sponsored Programs section for approval.
Transfer of equipment purchased by externally-sponsored research projects to another college or university will be made only on written approval by the State of Kansas Purchasing Director of a formal recommendation from the institution, including certification that:
The principal investigator is moving to another academic institution and his financial support is also transferred by the granting agency without interruption;
The granting agency approves transfer to the new institution of equipment purchased wholly by grant funds;
Such equipment was specialized in nature, acquired specifically for the investigator for his particular program, and is essential to continuance of the program without undue interruption in the work;
KSU does not need the equipment in its current related research program; and
The entire cost of physical transfer of the equipment will be borne by the granting agency or the recipient institution.
Most federal sponsors require equipment reports. The Division of Financial Services, Sponsored Programs section sends a notification to the department along with the form needed and asks that the form be completed and returned to Sponsored Programs for signature of the University official and mailing to the sponsor.
If title to equipment is not to KSU or not specified in the "agreement", a formal request may be issued. The request should be initiated by the principal investigator and can be requested anytime or included with the final equipment report. The Principal Investigator and the department head are to sign on all copies of the request and submit the original plus two copies to Sponsored Programs for signature of the University official and mailing to the sponsor.
Most federal sponsors require invention reports. The KSU Division of Financial Services, Sponsored Programs section sends a notification to the department along with the form needed and asks that the forms be completed indicating the status of inventions/patents. If an invention is included on the report, it must be processed through the KSU Research Foundation for signature and returned to Sponsored Programs. If no invention is included, the form should be returned to Sponsored Programs for signature of the University official and mailing to the sponsor.
The Department Head and Principal Investigator are responsible for the preparation and mailing of technical reports. However, the National Science Foundation (NSF) requires the monitoring of these reports by the KSU Division of Financial Services, Sponsored Programs on the quarterly financial report. The final project report (NSF Form 98A) is to be submitted within 90 days after the expiration date of the grant. The submission of the report within the 90 day period assures an orderly close out of completed grants and allows congress and other agencies in the scientific community early access to results of research supported by public funds.
NSF will forward a blank NSF Form 98A with a postage-paid return envelope for the final project report, to each Principal Investigator, for completion when the grant ends.
These final project reports are very important to NSF, and overdue reports probably will delay and/or reduce future awards. Department Heads and Principal Investigators are responsible for submitting the NSF final project reports in an accurate, complete and timely manner. In addition, a copy of the completed Form 98A must be sent to Sponsored Programs.
Per KSU administrative policies, when the termination date of a fixed-price sponsored project is reached and unencumbered funds remain in the project account, one of the following actions must be taken within three months:
1. Unused funds shall be returned to the sponsor, or
2. The award may be extended and funds expended during the subsequent budget period, provided they are applied to the activities specified in the project award notice, or
3. Unused funds may be transferred to a departmental Restricted Fees account to be used at the departments discretion. Total applicable indirect costs shall be deducted prior to the transfer of the funds, or
4. Remaining funds shall be treated as a regular indirect cost reimbursement and distributed in accordance with the University's policies for the type of project involved.
Shortly following the termination date, you will be notified in writing by the Division of Financial Services requesting that you indicate your choice for disposition of these residual funds. If none of the above actions are requested within three months of the termination date of the award, the Assistant Vice President for the Division of Financial Services has authorized Sponsored Programs to use item 4 mentioned above and close out the project account.
In the event that the termination date of a fixed-price sponsored project is reached and the project is overdrawn, and no action has been taken within three months, Sponsored Programs will have the option to transfer the payments equaling the overexpenditure to that department's Other Operating Expense (OOE) account, the department's Sponsored Research Overhead (SRO) account, or the department's Restricted Fees account.
OMB A-110, Section __.53 states that unless an earlier disposal date is authorized by the sponsor, all financial records, supporting documents, statistical records, and all other records pertinent to an award shall be retained for a period of three years from the date of submission of the final expenditure or for awards that are reviewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, as authorized by the Federal awarding agency unless you are notified to maintain them for a longer period because the records may be needed for audit purposes. However some State Agencies require that records be preserved for five years, therefore it is recommended that all records be preserved for five years. For further reference see Section 3000, Chapter 3090.
Statements, press releases and other documents describing projects funded in whole or in part with Federal funds shall clearly state the percentage of the total cost of the project which will be financed with Federal money and the dollar amount of Federal funds.
When a sponsored award is received, the sponsor's regulations and the standard State/University policies are to be followed. Basically, the only change is that the source of funds will be from a restricted fee account instead of state appropriations and the sponsor's requirements/regulations must be followed.
If assistance is needed, first consult the departmental Bookkeeper/Accountant who in turn may contact the following areas if further assistance is necessary.
- Source of salary forms need to be processed if salaries are involved. Refer to Business Procedures Manual (BPM) Chapters 1 and 2, or contact the KSU Division of Human Resources, Payroll Office, 532-6277 for assistance.
- Purchase of Services, Supplies and Equipment. University purchasing procedures are outlined in PPM Chapter 6310. In order to allow for the usual 30-45 days processing time for obtaining competitive bids and placing the order plus the vendor's delivery time, it is essential that the Principal Investigator requisition supplies and equipment immediately upon receipt of the award. If you have any questions or need assistance in preparing your Purchase Requisition, please contact Purchasing, at (785) 532-6214.
- Information on travel requests, and reimbursement procedures can be found in PPM Chapter 6410 or contact the Travel Section of the Division of Financial Services at (785) 532-7356 for assistance. For anticipated foreign travel plans, contact the department accountant immediately.
- Invoice and expenditure reports: refer to PPM Chapter 7050.090 thru 7050.150 or contact the KSU Division of Financial Services, Sponsored Programs for assistance at (785) 532-6207.
- Principal Investigators should work closely with departmental Bookkeepers/Accountants to determine the reasonableness, allocability and allowability of costs. OMB Circular A-21 explains this information in detail.
Copies of the Office of Management and Budget Circular A-21 - Cost Principles for Educational Institutions and the Office of Management and Budget Circular A-110 - Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals and Other Non-Profit Organizations are available in the KSU Division of Financial Services, Sponsored Programs, Room 10, Anderson Hall.
If you have any questions on any of the post award procedures, please contact the KSU Division of Financial Services, Sponsored Programs, at (785) 532-6207.