Post-Award Grant Financial Management

Grants Management

Financial activity should be monitored on a timely basis to ensure proper posting of expenditures and accurate financial reporting.

The Federal Office of Management & Budget has established OMB Circulars as a government-wide guidance to manage sponsored agreements. The OMB circulars provide uniform standards. As an educational institution, Towson University must comply with the following regulations:

• OMB Circular A-21 Cost Principals- Financial Requirement

The cost principals provide uniform standards for determining costs that are:

• Reasonable -reflects whether the individual acted with due prudence
• Allocable- the cost has a direct benefit to the project being charged
• Allowable-the cost is allowed by federal regulations, sponsor terms and conditions, including program specific requirements
• Treated Consistently – like costs in similar instances are treated consistently throughout the University

• OMB Circular A-110 Administrative Requirements for Grants
• OMB Circular A-133 Audit Requirements

In addition to the federal OMB Circulars, Towson University must comply with sponsor's guidance, policy manual, terms and conditions, and program specific requirements.

• Time & Effort Reporting/Release Time

As required by OMB Circular A-21, all Faculty and Staff working on sponsored agreements are required to complete a time and effort report. If a time card is submitted and/or effort is charged directly to the project, a Time & Effort report is not required. Time & Effort reports are an after-the-fact confirmation of actual time dedicated to a project. Total distribution of effort dedicated to all university activities should total 100%. One hundred percent effort is defined as the effort expended to accomplish the set of activities encompassed by the appointment, regardless of the actual hours expended on those activities. Effort should be consistent with the expectations of the individual's institutional appointment(s) such as teaching/instruction, research/scholarship, and administration. Activities such as proposal writing, consulting and/or other outside professional activities, leadership in professional societies, activities associated with appointments at other affiliated entity should be excluded from institutional workload. Please refer to the Faculty Handbook Chapter 3, part III, section XV. http://www.towson.edu/provost/resources/toc.asp

Release time spent on a sponsored project, in-kind effort (whether mandatory or voluntary committed), and effort underwritten by the sponsor must be documented.

In-kind committed effort is time a faculty member has agreed to commit to a sponsored project, but the cost is not charged directly to the project.

If a faculty member receives release time to work on a sponsored project and the effort is underwritten by the sponsor, Academic Affairs will receive a portion of the amount calculated for release time to cover the actual cost of hiring a replacement to teach the course load.

Please refer to the Faculty Handbook Chapter 9, part II, section VII.

Faculty Time & Effort reports are due at the end of each semester.
Staff Time & Effort reports are due at the end of each month.

Time & Effort Report form and instructions can be found here.

A sample report can be found here.

Important note: Prior approval by the sponsor is required if key personnel named in the award changes or level of effort changes more than 25% (except where the sponsor's policy is stricter). Prior approval is also required if the Principal Investigator will be absent from campus more than three (3) months.

• Subawards

A subcontract/subaward is an award of financial assistance to an eligible subrecipient under a grant or cooperative agreement.
If funds awarded to Towson University are subcontracted to another institution or organization (subrecipient), please contact OSPR. OSPR will assist you in establishing a subcontract agreement with that institution or organization.

Determination of Subrecipient or Professional Service Vendor

• Subrecipient:
• Performance is measured against whether the scope of work is met
• Has responsibility for making programmatic decisions
• Has responsibility for adherence to applicable program compliance requirements(e.g. OMB Circulars, sponsor regulations)
• Uses the funds to carry out a project as compared to providing goods or services for a project
• Professional Service/Vendor:
• Provides goods or services within normal business operations
• Provides similar goods or services to many different purchasers
• Operates in a competitive environment
• Provides goods or services that are ancillary to the operation of the research project
• Is not subject to program compliance requirements

Federal regulations found in the OMB Circulars A-21, A-110 and A-133 also flow down to the subrecipient. The Principal Investigator is responsible for monitoring the subrecipient's technical and programmatic activities to ensure project objective(s) are being met and are in compliance with federal and agency regulations. The Principal Investigator is also responsible for approving and signing all invoices submitted by subrecipient.

• Subrecipient invoices should include the following:
• Project Name
• Towson University's contract number
• Approved budget
• Current period expenditures
• Total expenditures to date
• Remaining balance
• Fiscal agent certification

Post-Award and the Principal Investigator will review subrecipient's detail transaction reports and perform random audits of expenditures.

• Cost Sharing

Cost sharing is project costs that are not reimbursed by the sponsor.
Types of cost sharing:

• Mandatory – committed, required by the sponsor as a condition of the award
• Voluntary Committed - not required by the sponsor, offered by the Principal Investigator as a demonstration of commitment to the project
• Voluntary Uncommitted - not required by the sponsor and is above the committed and budgeted cost share, does not need to be tracked or certified

Committed cost share, whether mandatory or voluntary, is a binding obligation that is auditable and must be accounted for and documented.

• Federal regulations stipulate that:
• Federal funds cannot be used to meet cost sharing obligations
• Costs used to meet cost sharing obligations cannot be claimed for other federally funded projects
• Costs claimed as cost sharing must be verifiable, allowable, and reasonable.

Cost sharing methods:
In-kind Contributions - existing cost covered by the University's operating budget (e.g. effort of faculty that is devoted to project, but not paid by the sponsor, waived fees, and/or waived F&A).
Cash Contributions - new costs requiring additional funds, which is covered by the department or with prior approval, Towson University's matching cost pool.
Third party Contributions - external organization's cash contributions, donations, equipment, supplies, services, etc.

Principal Investigator must document all committed cost sharing. At the conclusion of the project, the Principal Investigator must submit a Cost Share Documentation form to Post-Award Grants Financial Management.

• Budget Revisions

The budget plan is the financial expression of the project or program as approved during the award process. Budget revisions may be necessary if actual needs of the project change.

Many sponsors allow budget revisions among budget categories without prior approval if the project scope remains the same and/or the revision does not exceed a predetermined amount or percentage.

Refer to the sponsors terms and conditions to determine if and when prior approval is required.

If prior approval is required from the sponsor for budget revisions, requests must be submitted through OSPR. If a sponsored agreement receives supplemental funding, the budget must be submitted through OSPR. Please contact OSPR for assistance.

If prior approval is not required from the sponsor for budget revisions, an internal request must be submitted to Post-Award via the Budget Revision form.