Louisiana State University Medical Center
Sponsored Projects Manual

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ADMINISTRATION OF APPROVED PROJECTS

| Acceptance of the Award | Budget Modification | Actions Requiring PHS Prior Approval | Progress Reports | Personnel Policies & Compensation |Certification of Time and Effort | Travel | Equipment | Change of Principal Investigator | Change of Institution | Termination of a Grant |


A. Acceptance of the Award: The signature of the Vice Chancellor of the Health Sciences Center represents the acceptance of the grant award. For most grant awards this signature is affixed to the grant application and no further action is required. Funds are awarded to the institution and not directly to the Principal Investigator and as a consequence, all university policies on use of funds apply. The LSUHSC retains the right at any time to refuse to accept an award or terminate a funded program.

Contracts differ from grants in that the proposal is a less formal document and the official signature on these documents indicates the willingness of the LSUHSC to negotiate a contract agreement for the work in the area of the proposal. The contract agreement does not become final until it has been accepted by an official of the funding agency and the LSUHSC as signified by the signatures.

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B. Budget Modification (Rebudgeting): The LSUHSC procedures for rebudgeting are based on the authority delegated by the PHS Grants Policy Statement. All rebudgeting actions begin with the Principal Investigator of the grant and cannot take place without his/her approval. To initiate the action a Rebudget Form (sample in appendix) is secured from the Office of Sponsored Projects, and the Principal Investigator completes the Grant Number, LSUHSC Account Number and item A. He/she affixes signature and date and routes the form to the appropriate dean. After the dean certifies and signs, the form is then sent to the Grants Accounting office for final disposition and signature of Vice-Chancellor. A letter of justification for the requested rebudget must accompany the form as well as a Request for Purchase if the rebudget is to purchase equipment.
  PRIOR APPROVAL AUTHORITIES GIVEN TO GRANTEES

Except as otherwise provided, grantees may exercise prior approval authority for the items listed below. For rebudgeting actions, prior approval is required whether increasing an existing budget category or using funds for items not in the originally approved budget. In all cases the costs must be considered necessary to the conduct of the project and must be allowable under the award.

  1. Special Purpose Equipment. Cost of acquisition not to exceed $25,000 per item.
  2. General Purpose Equipment . Cost of acquisition not to exceed $25,000 per item.
  3. Patient Care Costs . Amounts in excess of that in the approved budget, provided the need for patient care in the project was specifically approved by the PHS awarding office.
  4. Domestic and Foreign Travel.
  5. Contracts for Management Services . Not to exceed $25,000.
  6. Insurance .
    a. Contributions to a reserve fund for a self-insurance program.
    b. The cost of insurance on Federal Government-owned equipment.
  7. Public Information Service Costs . (News releases).
  8. Publication and Printing Costs . Not to exceed $25,000 for a single publication.
  9. Alterations and Renovations (A & R) Not to exceed $25,000 in a budget period. Funds awarded and rebudgeted amounts for alterations and renovations may not exceed the lesser of $100,000 or 25 percent of total direct costs during any consecutive 3-year period.
  10. Audiovisual Materials . The cost of acquisition or production not to exceed $25,000 for a single audiovisual product.
  11. Trailers and Modular Units . Applicable only to those units classified as equipment.
  12. Pre-Award Costs . A grantee may, at its own risk, incur obligations and expenditures to cover costs prior to the effective date of an award. However, for new and competing continuation awards, grantees may authorize pre-award costs only under the following conditions:
    a. The costs are incurred within 90 days prior to the effective date of the award.
    b. The application has been recommended for approval by an objective review group or, when applicable, by a National Advisory Council.
    c. When required for specific expenditures or activities, prior approval from PHS has been obtained. Additionally, the approval of costs prior to the award imposes no obligation on the Federal Government to make the award or to increase the amount of the approved budget.
  13. Consultant Fees . Compensation beyond that included in the base salary for professional staff of educational organizations, for consultation across departmental lines or which involves a separate or remote operation, and the work performed by the consultant is in addition to his or her regular workload provided that the consulting arrangement does not:
    a. Constitute a transfer of substantive programmatic work;
    b. Result in a contract for management services which requires PHS prior approval; or
    c. Need PHS prior approval because of program regulations or other award terms.
  14. Participant Support Costs . Applicable to training grants only. Participant costs are direct costs for items such as subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with meetings, conferences, or symposia.
  15. Extensions of Budget Periods. For those grants under expanded authority up to a one year extension may be granted internally.
  16. Carryover of Unobligated Balance. For those grants under expanded authority grantee organizations have the authority to approve carryover of funds.

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C. Actions Requiring PHS Prior Approval: For discretionary grants other that construction grants, grantees must obtain written prior approval from the Grants Management Officer of the PHS awarding office for the following postaward changes. However, for recipients of certain PHS research grants, PHS has extended additional authorities. (See Prior Approval Authorities Retained for Certain Research Grants below). For those rebudgeting actions listed below, prior approval is required whether increasing an existing budget category or using funds for categories not in the originally approved budget. Failure to obtain prior approval, when required, from the appropriate PHS awarding office may result in the disallowance costs. However, grantees may request retroactive approval from the PHS awarding office. There may be other prior approval required by the Notice of Grant Award (G), specific program legislation, or regulations. Therefore, the following list may not be all inclusive. For State and local governments and federally recognized Indian tribes, PHS has waived the 5 percent cumulative threshold contained in 45 CFR Part 92.30 and only the items listed below must receive PHS prior approval.
  PRIOR APPROVAL AUTHORITIES RETAINED BY PHS FOR RESEARCH GRANTS
  1. Change of Scope or Research Objectives. The grantee organization is required to seek approval from the awarding component when there is a change in the scope or research objectives of the project. Actions likely to be considered a change in scope or objectives include, but are not limited to, the following.
    a. A change in the specific aims approved at the time of award.
    b. Substitution of one animal model for another.
    c. Any change from the approved use of animals or human subjects.
    d. Shifting the emphasis of the research from one disease area to another.
    e. Applying a new technology, i.e., changing assays from those approve to use of a different type of assay.
    f. Transferring the performance of substantive programmatic work to third party by contract or any other means.
    g. Change in key personnel whose expertise is critical to the approved project.
    h. Significant rebudgeting - whether or not it requires approval under rules governing budget changes. NIH Policy considers cumulative rebudgeting of more than 25% of the award a change in scope of project.
    i. Incurrence of patient care costs where the need has not previously been approved by PHS and/or when a grantee desires to rebudget funds out of the patient care category.
    This list clearly is not all-inclusive. In the event of uncertainty as to whether a particular change is significant enough to require prior approval, questions should be referred to the Grants Management Officer of the awarding component for final determination.
  2. Change in Principal Investigator (PI). The grantee organization is required to seek approval in writing before a substitute PI is appointed to replace an absent or departed PI. If the PI is absent from the project for a period of 3 months or more, a substitute PI must be proposed by the grantee organization and must be approved by the PHS awarding component. The request for approval of a substitute PI should include a justification for the change, the curriculum vitae of the individual proposed, and any budgetary changes resulting from the proposed change.
  3. Change of Grantee Organization. PHS awarding component approval is required to transfer a grant from one organization to another. PHS awarding component approval is also required for successor-in-interest situations. A successor in interest may occur as a result of a merger, divestiture, or other corporate change in which all or part of the assets involved in the performance of the grant supported entity(ies) are transferred to another entity.
  4. Actions Requiring Additional Federal Funds. PHS awarding component prior approval is required if the grantee organization takes action that generates a need for additional Federal funding to carry out the project.
  5. Retention of Research Grant Funds When a Research Career Development Award (RCDA) is Awarded. Funds budgeted in a individual's salary and/or fringe benefits but freed as a result of receiving and RCDA for that individual may not be used for any other purpose without the prior approval of the PHS awarding component.
  6. Award Terms and Conditions. Deviations from special terms or conditions stated on the Notice of Grant Award require prior approval from the PHS awarding component.
  7. Closely-Related Work. When salaries and/or other activities are being supported by two or more technically related PHS grant projects under the direction of the same Principal Investigator/Project Director and funded by the same awarding component, grantees may charge costs to the project for which the costs are originally approved or to another closely-related PHS project only with the prior approval of the PHS awarding component.
  8. Audiovisuals and Publications. Approval by the Office of the Assistant Secretary for Public Affairs of acquisition or production of audiovisual material exceeding $25,000 for a single audiovisual product and publication and printing costs exceeding $25,000 for a single publication.
  9. Pre-Award Costs Incurred More Than 90 Days Prior to the Effective Date of Any New or Competing Continuation Award. The incurrence of costs prior to the award of a grant imposes no obligation on the Federal Government to make the award or increase the amount of the approved budget.
  10. Drawings/Specifications for Alterations and Renovations Over $25,000. In addition, costs for alterations and renovations may not exceed the lesser of $150,000 or 25 percent of total direct costs during any consecutive 3-year period unless a waiver is obtained.
  11. Indemnification Against Third Parties
  12. Extensions of Budget Periods. For those grants under expanded authority PHS approval is needed to extend the grant beyond the one year extension obtained under the internal prior approval system. For all grants not under expanded authority, any extension requires PHS approval.
  13. Capital Expenditures for Land and Buildings. Although not prior approval items for grants subject to expanded authorities, PHS does require timely notification when the grantee carries over unobligated balances of grant funds or extends the final budget period within the project period.
  Methods of Grantees to Request Approvals: Under discretionary grants, all requests that require PHS awarding office prior approval must be submitted in writing to the Grants Management Officer designated on the Notice of the Grant Award. All requests must bear the signature of an authorized official of the business office of the grantee organization, who for LSUHSC is Peter Tiskus, as well as the principal investigator or program or project director. The Grants Management Officer shall be responsible for reviewing the request with PHS program officials, as necessary, and for informing the grantee in writing of the final disposition of the request.

Grantees should ensure the written approval or disapproval of such requests is signed (or countersigned) by the Grants Management Officer who signed the Notice of Grant Award, a grants management staff member acting for that official, or the individual identified at the time of award as the grantee's business management contact within PHS. Grantee's who take action on the basis of letters by unauthorized officials do so at their own risk. Such responses will not be considered binding by or upon the Public Health Service.

Whenever grantees contemplate rebudgeting or other postaward changes and are uncertain about the allowability of types or levels of cost or an activity(ies), particularly when such items are not mentioned in the regulations, cost principles, or other HHS or PHS policy documents, they are strongly encouraged to consult in advance with the designated Grants Management Officer.

Failure to obtain prior approval when required from the appropriate PHS awarding office may result in the disallowance of costs. However, grantees may request retroactive prior approval from the PHS awarding office.

Additionally, even where the grantee has responsibility for rebudgeting actions, if it is determined, through audit or otherwise, that the costs do not meet the required tests of allowability, applicability, reasonableness, etc., the costs may be disallowed.

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D. Progress Reports : The Principal Investigator is responsible for complying with all report requirements and filing deadlines as specified by the supporting agency. If these reports are not part of a continuing application, a copy should be sent to the Office of Grants & Governmental Programs.

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E. Personnel Policies & Compensation: Personnel employed by the LSUHSC to conduct research supported through extramural grants and contracts are employees of the State of Louisiana. As such, their classification, compensation, and termination must be conducted in accordance with LSUHSC policies. All such personnel actions must have the concurrence of the appropriate Department Head and Dean.

To avoid possible confusion, Principal Investigators who are preparing grant and contract proposals should contact the Office of Human Resource Management to assure that all technical and clerical positions are properly classified and that the level of compensation requested from the supporting agency is in keeping with the level of classification.

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F. Certification of Time and Effort: The Principal Investigator must attest that the salaries charged to a project accurately represent the proportion of the individual's time and effort actually spent on the project by signing the time and effort report.

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G. Travel : The State of Louisiana Travel Regulations govern reimbursement for travel performed with project funds. Prior approval is required and all travel questions should be directed to the LSUHSC Travel Auditor 568-4695.

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H. Equipment : Permanent equipment purchased from project funds is owned either by the LSUHSC or the supporting agency, depending upon the terms of the grant or contract. In either case, the Principal Investigator is responsible for such equipment and must account for all items periodically.

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I. Change of Principal Investigator : Whenever an individual is unable to continue serving as a Principal Investigator on an extramural project, the Head of Department (generally with agency approval) should appoint a new project director. Whenever absence of the Project Director or Principal Investigator is anticipated to exceed three months, the LSUHSC must submit its plans for continuing the project to the granting agency. The NIH requires that this plan be approved by its representative at least thirty days prior to the departure of the Principal Investigator. These requirements differ between agencies, and it is the responsibility of the Principal Investigator to assure that agency guidelines are followed. Failure to comply with agency regulations could result in termination of the project.

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J. Change of Institution: When a Principal Investigator terminates his/her association with LSUHSC and requests a transfer of extramural support to another institution, specific approval must be obtained from both the LSUHSC and the funding agency. This is referred to as a Change of Grantee Institution and is the process whereby the legal and administrative responsibility for administering a grant supported project or activity is transferred from one legal entity to another before the expiration date of the approved project period for the grant being transferred. Forms are available for NIH and NSF grants. Samples are included in Appendix.

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K. Termination of a Grant: Research Agreements with extramural support agencies are without exception for a specified period of time and as such all expenditures incurred for the Agreement must be for the period of the Agreement. The Investigator should make every effort to complete the research within this period of time. If the funds paid to the LSUHSC are provided on a cost reimbursement basis (federal grants and contracts), further charges cannot be made against this award without special permission from the granting agency. If it is determined that it will not be possible to complete the proposed studies in the specified time frame, the Principal Investigator should request ano-cost extension to the grant or contract. This permission allows previously awarded funds to be used but does not provide any new monies. The letter requesting the extension will not be accepted by the federal agency unless it is countersigned by an institutional official, usually the Vice-Chancellor for Academic Affairs.

If the program is to terminate, three items are generally required by the granting agency: 1) a final Progress Report; 2) a Final Invention Statement and 3) a final Report of Expenditures. The Progress Report and the Invention Statement are the responsibility of the Principal Investigator and must be provided. The Grants Accounting Office will provide the final Report of Expenditures directly to the Granting Agency. Failure to provide this material could result in the Principal Investigator being barred from further consideration for research support.

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The statements found on this page are for informational purposes only. While every effort is made to ensure that this information is up-to-date and accurate, for official information please consult a printed University publication.

Last revised: 08/17/98