Pre-Award Policies & Procedures
Hartwick College’s internal grant approval process begins at the department level with the Principal Investigator/Project Director (PI/PD) discussing his/her project idea with the department chair. If the chair supports the project, the PI/PD must submit a brief description to the Provost and Vice President for Academic Affairs’ office prior to contacting the Director of Corporate, Foundation, and Government Relations.
The Grant Project Clearance Form is an internal form used to compile relevant information regarding proposals for external funding and to confirm compliance with College policies and sponsor/federal regulations. The Principal Investigator/Project Director is responsible for completely filling out the form and securing required signatures. The Office of Corporate, Foundation, and Government Relations retains copies of the signed Grant Project Clearance Form.
Grant Project Clearance Form
Authorization, Internal Approval, and Signatory Authority
All grant proposals and applications are subject to internal approval. All faculty who intend to submit a proposal must first discuss the project with their department chair to determine if their time commitment, use of College equipment or space, or travel will impact their teaching and advising responsibilities or the functioning of the department. The Provost and Vice President for Academic Affairs must also review all applications and approve grant submissions that involve the use of institutional resources, including course release or faculty leave, or the commitment of institutional match or cost share. The Controller reviews all budgets prior to submission to insure allowability of costs. It is the responsibility of the PI/PD to allow adequate time to obtain approvals prior to the grant submission deadline.
The Director of Corporate, Foundation, and Government Relations is the authorized organizational representative for Hartwick College for electronic submission via FastLane and Grants.gov. The official signatory for all grants for Hartwick College is Dr. Margaret Drugovich, President. Dr. Drugovich has the authority to formally commit Hartwick College resources and to accept federal funds on behalf of the College.
The Grant Project Clearance Form is required for all proposals that:
- require a signature from an “Authorized Organizational Representative”
- will result in a grant being paid to and administered by the College
- commit College employee time (other than faculty time that is within the terms of their contract)
- commit use of College equipment or space (other than faculty offices)
- commit, explicitly or implicitly, College funds (other than faculty leave salary)
- commit the College to a future action (such as offering a new course developed with grant funds)
The Grant Project Clearance Form must be signed by:
- Principal Investigator/Project Director
- Department Chairperson
- Provost and Vice President for Academic Affairs
Additional approvals are required for course release time, creation of new positions and hiring of personnel, use of certain equipment and facilities, and research with human subjects (including questionnaires), vertebrate animals, or genetic, biohazardous, or radioactive materials. Only the Institutional Review Board and committees that oversee these matters for the College, or appropriate administrators, can determine if a proposal is exempt from review.
Electronic signatures can suffice in most instances, but the Provost and Controller must see all Grant Clearance Forms and communicate approval to the Director of Corporate, Foundation, and Government Relations.
Post Award Policies & Procedures
Responsibilities of the Principal Investigator/Project Director
The Principal Investigator/Project Director (PI/PD) is responsible for the successful conduct of the project in accordance with all applicable policies of Hartwick College, the federal government, and the grantmaking entity.
A Grant Administration document will be created when an external grant is awarded and a meeting will be held with the PI/PD, Controller, and Director of Corporate, Foundation, and Government Relations in order to review grant terms and conditions and the project budget. The PI/PD and the Controller sign the Grant Administration document.
In addition, the PI/PD must:
- Submit or forward electronic copies of original award documents to the Office of Corporate, Foundation, and Government Relations.
- Read all terms and conditions of the grant and all award and administration guidelines of the granting agency i.e. NSF’s Proposal and Award Policies and Procedures Guide, NEH’s Grant Terms and Conditions.
- Administer the project in order to meet the goals and objectives of the original proposal.
- Comply with all terms and conditions of the grant, and with all College policies for the administration of grants including allowability of costs and conflict of interest.
- Submit funds received to the Controller’s office (grants accountant).
- Monitor expenses based on monthly reports provided by the Business Office and limit expenditures to the total dollar amount awarded.
- Authorize grant spending (Hartwick’s policy requires two signatures on all grant expenditures, including reimbursements for travel costs made to the PI/PD). All purchase orders for grants are approved by Academic Affairs, interim and final financial reports are compiled by the Controller’s office.
- Submit all receipts for grant expenditures to the Business Office with reimbursement requests. All grant expenditures must correlate with the original costs described in the project budget, unless a change has been authorized and Prior Approval form submitted. All expenditures must be made at least 30 days before the end of the grant period.
- Submit all required interim and final narrative reports to the Office of Corporate, Foundation, and Government Relations which will coordinate report submission, except in the case of granting agencies that have online report systems, such as NSF’s FastLane which is accessed by the PI/PD.
- Oversee hiring of all project personnel compensated in the grant, supervise the work of all grant-funded employees, and maintain documentation of time and effort of all project personnel.
- Monitor all sub-awards associated with the grant.
- Provide the Office of Corporate, Foundation, and Government Relations with copies of all grant-related correspondence.
- Work with the Controller to prepare interim and financial reports and grant closeout
request approval from the Controller’s office for any changes to approved budgets or other terms of the grant.
- Notify the Director of Corporate, Foundation, and Government Relations if there are any changes to the project that effect the achievement of objectives or involve budget revisions.
- Retain project data and data sharing systems in compliance with sponsoring agency requirements.
Responsibilities of the Controller’s Office
The Controller serves as the grants accountant and is responsible for the overall financial administration of all grants to the College. The Controller’s Office follows standard accounting practices and adheres to all College policies and federal regulations regarding allowability of costs and auditing of budgets. Specific responsibilities include:
- Setting up all grants in the accounting system.
- Preparing all financial reports, including monthly reports provided to the PI/PD
requesting reimbursements/drawing down funds from sponsoring agencies for grant-funded expenses.
- Authorizing changes to approved budgets or other grant terms (in accordance with sponsoring agency policy).
- Certifying compliance with all grant-related federal regulations.
Prior Approval System
Overview of Federal Regulations
OMB Circular A-110, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations governs the administration of all federal grants, including changes to grant-funded projects. Recipients are required to report deviations and request prior approvals for budget and program plan revisions, in accordance with Section 25 of OMB Circular A-110. Prior approval means written approval by an authorized official evidencing prior consent.
Before making any project changes, the Principal Investigator/ Project Director must consult with the Director of Corporate, Foundation, and Government Relations. Internal approvals will be sought from the Controller and/or the Provost. All approvals must be documented to provide assurances to the appropriate federal agency.
Prior Approval Form
For non-construction awards, prior approval from Federal awarding agencies is needed for one or more of the following program or budget related reasons:
- Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval).
- Change in key project personnel specified in the application or award document.
- The absence for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
- The need for additional federal funding.
- The transfer of amounts budgeted for indirect costs to absorb increases in direct costs, or vice versa, if approval is required by the federal awarding agency.
- The transfer of funds allotted for training allowances (direct payment to trainees) to other categories of expense.
- The sub-award, transfer, or contracting out of any work under an award. This provision does not apply to the purchase of supplies, material, equipment or general support services.
Once reviewed and approved by the Provost and Controller, the request will be submitted to the funding agency by the Office of Corporate, Foundation, and Government Relations.
Institutional Prior Approval
The OMB Circular and federal agencies delegate some authority to institutions to approve certain administrative actions. Hartwick College has instituted an Organizational Prior Approval System to ensure that adequate reviews and approvals are in place for decisions that affect the administration of grant-funded projects. Administrative changes include:
- Pre-award spending
- No-cost time extensions
- Changing budget lines within the categorical budget
The Principal Investigator/Project Director is authorized to make charges to grants provided that they agree with the approved budget. Changes to budgets are permitted if they:
- Are allowable under OMB Circular 21: Cost Principles for Educational Institutions
- Are consistent with the terms and conditions of the award and with sponsor and Hartwick College policies
- Do not constitute a change in project scope
- Are reasonable, necessary, and allocable to the project
Before incurring any charges that deviate from the awarded budget, the PI/PD must submit a Prior Approval form to the Director of Corporate, Foundation, and Government Relations, who will review it with the Controller and Provost, and obtain the necessary signatures. The signed OPAS form is retained in the grant file for three years following submission of the final financial report.
Time and Effort Reporting Policy
Federal Regulations of OMB Circular A-21
Under the provisions of the Office of Management and Budget Circular A-21, the federal government requires an effort report when an individual is compensated by, or has agreed to contribute time to, a federally-sponsored project. All employees funded with federal dollars must complete time and effort reports. All faculty who serve as investigators on sponsored agreements are personally responsible to certify the amount of effort that they and their employees spend on sponsored activities.
Time and effort reporting is required when any part of an individual’s salary is charged to a federal program or used as match for a federal program. This requirement is subject to audit, unallowable costs are subject to repayment, and irregularities with reports can be cause for institutional or individual disallowances.
All individuals who devote effort to sponsored activities, whether or not they are paid, are subject to effort reporting. Faculty, regardless of their role on the grant must certify their own effort reports. The Principal Investigator must certify the work of non-faculty project staff charged to the grant. These reports not only document the distribution of effort but also the appropriateness of salary and wage charges to federal grants and contracts.
(OMB Circular No A21 J10c(2))
Time and Effort Certification Form
Definition of Effort
Effort is defined as the amount of time an employee devotes to fulfilling his/her College responsibilities. Effort reporting certifies that:
- Effort supported (paid) by a federally-sponsored project has been performed as promised.
- Effort expended in support of a federally-sponsored project, but not paid by the project, has been performed as promised.
(OMB Circular No A21 J10c(2)(a)-(f))
Effort is the portion of time spent on a particular activity, expressed as a percentage of the individual’s total activity for the university. It is NOT based on 40 hour work week, but on 100% of faculty activities including instruction, administration (chair, dean responsibilities) committee service, research without external funding, and sponsored project activities.
If a PI works 60 hours per week, 30 hours represents 50% effort
Estimate of weekly hours spent on the sponsored project divided by total hours in an average work week equals effort on the sponsored project.
The effort percentages must total 100%.
Time and Effort Reporting
Time and effort reporting makes salary sources for the period congruent with effort spent for the period. Distribution of effort should represent a reasonable estimation of the actual effort expended during the term being certified. There is no standard form.
(OMB Circular No A21 J10b(1))
Semi-Annual Certification Report
Hartwick College uses after-the-fact time and effort certification. The Office of Corporate, Foundation, and Government Relations will distribute report forms at the end of each semester and the summer. Report periods are defined as, Fall Semester: September through December inclusive, Spring Semester: January through May inclusive, and Summer: June through August inclusive.
The semi-annual certification report must be submitted to the Controller no later than 15 days following the end of each semester and summer. These must be signed by the employee or supervisor with first-hand knowledge of the work. There must be documentation to verify the underlying basis of the report, actual effort, not estimated effort. PIs are advised to consult supporting documentation when completing reports i.e. calendar, work product, time log, etc. Audits have specifically reviewed the documentation used in completing reports.
Auditors will comment on any of the following:
- Late reports
- Effort certified by someone without first-hand knowledge
- Percentage outside of sponsored project not credibly sufficient to cover teaching, clinical, administrative or other university work.
- Revisions to Time and Effort Reports
- Significant data inconsistency between effort report and other documentation such as:
o Clinical time reports
o Outside activity forms
o Other support forms
o Leave reports
(OMB Circular No A133 Section_.525(d)(1) regarding audits )
Compliance with time and effort reporting has become more stringent and is subject to audit. Federal auditors include effort reporting as a specific audit focus. Each individual is responsible for certifying his/her own effort, which is NOT based on a 40 hour work week. It is based on the individual’s own work week. Effort reporting tracks the reasonable estimation of actual activity on projects and should not simply mimic budgeting amounts.
NSF Proposal Guide
Time and Effort Certification Form
Responsible Conduct of Research Policy
Responsible Conduct of Research Training Policy
Background: Effective January 4, 2010 the National Science Foundation requires that “When submitting a proposal to NSF, the Authorized Organizational Representative is required to complete a certification that the institution has a plan to provide appropriate training and oversight in the responsible and ethical conduct of research to undergraduates, graduate students, and postdoctoral researchers who will be supported by NSF to conduct research.” NSF may, at their discretion, audit compliance with the plan.
NSF policy and FAQs
Responsible Conduct of Research training is required for all students and postdoctoral fellows who receive salary and/or stipend support for research on NSF grants or who work as volunteers or receive academic credit for participating in NSF-funded research. Training must be completed within the semester or summer that the student begins work on the NSF-funded research and needs to be completed only once during their tenure at Hartwick College. Principal Investigators have the primary responsibility of ensuring their students complete the required training. The Checklist for Submitting a Grant Proposal requires a signature from any PI who submits an NSF proposal that requests funding for undergraduate students. This signature indicates that the PI agrees to participate in appropriate RCR training.
The Director of Corporate, Foundation, and Government Relations will notify the Provost when the College receives a grant from the National Science Foundation, providing the name of the PI and the NSF grant number. PIs will provide the names of the students participating in the research. The Provost will send reminder e-mails to all faculty who are PIs on NSF grants at the beginning of each grant period.
Each student must complete the Collaborative Institutional Training Initiative (CITI) Course in the Responsible Conduct of Research.
Hartwick subscribes to the free training modules at CITI.
Upon completion of the CITI module, certification will be e-mailed to the CITI Administrator and copied to the Office of Corporate, Foundation, and Government Relations and the Provost’s Office. The Director of Corporate, Foundation, and Government Relations will maintain a file for each NSF funded grant, listing PI, the names of students involved with the project, and the dates of completion of CITI training