Grant Management Handbook

SUBRECIPIENT SERVICES

There may be circumstances where the University will partner with another entity to provide services within the grant project. When this occurs, please work with the Director of Post-Award Services to draft a Subrecipient Agreement. The Subrecipient Agreement includes activities and responsibilities for all parties and is time-sensitive. The Subrecipient Agreement also specifies terms regarding budget, reporting requirements, timeframe for meeting objectives, and recordkeeping. The Director of Post-Award Services will facilitate the process of preparing and authorizing all subrecipient contracts/agreements. The Director of Post-Award Services will ensure that the Principal Investigator receives a copy of the fully signed and authorized contract/agreement.

Risk Assessment Process

UVU has adopted the use of a Subrecipient Commitment Form – Risk Assessment Questionnaire to be used prior to a subrecipient award being issued, and a Continuing Assessment Tool (CAT) Form to be used for ongoing risk assessment at least every two years after an award has been issued. The Office of Sponsored Programs has also designed a procedure to assess and communicate project status with the subrecipient project director/investigator as follows:

Before a subrecipient contract may be approved, a potential subrecipient is given the Subrecipient Commitment Form – Risk Assessment Questionnaire and the OSP Director of Post-Award Services conducts an assessment of the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient status to include consideration of such factors as: 1) The subrecipient's prior experience with the same or similar subaward; 2) the results of previous audits including whether or not the subrecipient receives a Single Audit, the extent to which the same or similar subaward has been audited as a major program, and if there have been recent audit findings; 3) Whether the subrecipient has new personnel or new or substantially changed systems; and 4) The extent and results of Federal awarding agency monitoring. The Senior Director of Sponsored Programs will review the risk assessments and monitoring for sufficiency.
If the potential subrecipient or their personnel have limited or no experience with federal awards, have had findings of concern in past audits, or trouble with past federal monitoring activities, they will be considered medium-risk subrecipients and if they choose to accept a contract with UVU, they must agree to be subject to assessments on a quarterly basis of all expenditures to include a review of all source documentation and budget assessment, an annual audit review, and a possible site review (depending on proximity to UVU, award size, and other contingent factors). An organization will be moved from medium-risk to low-risk if they continue for a year without substantive findings or concerns from these reviews. If the potential subrecipient has had substantial findings in past audits, or have had a history of significant problems with recent federal agency monitoring, they will not be given further consideration as a potential subrecipient.
Subrecipients that currently are under contract with UVU or have had recent contracts within the past year, will be given the Continuing Assessment Tool (CAT) Form to complete on an annual basis if they are medium-risk subrecipients, and on a biennial basis if they are considered low-risk subrecipients. Low-risk subrecipients may also receive a site visit at least once every two years (depending on proximity to UVU, award size, and other contingent factors) and will be required to report any findings from their annual audit or a recent program audit. During these reviews, if subrecipients have had findings of concern in recent audits, or trouble with monitoring activities, they may be considered medium-risk subrecipients and become subject to assessments as described in part two above. For organizations that have been considered medium-risk organizations and have continued to have audit findings or trouble with other monitoring, or low-risk organizations that have had substantial findings in audits or other monitoring activities, the OSP may determine that they are high-risk organizations and require such measures as pre-approval on all expenditures, elimination of procurement credit cards attached to the grant account, more frequent monitoring visits, an annual review of their audits, or other measures as deemed necessary to assure compliance with federal, state, and organizational regulations. The Director of Post-Award Services will work with PIs to assist them in helping subrecipients with compliance problems as needed. After a year, an organization may be moved from high-risk to medium-risk if they continue for a year without substantive findings or concerns from reviews. When appropriate, contracts may be terminated for cause.
In all cases, organizations and/or their principal members that are currently debarred or suspended will not be allowed as subrecipients of federal grants through UVU.
The OSP Director of Post-Award Services will be responsible for subrecipient risk assessments which will be conducted annually or more frequently if needed. The Director of Post-Award Services will notify the Senior Accountant of Grants and Contracts, the PI, the subrecipient, and other related UVU personnel if a subrecipient is considered to be a medium or high-risk entity and will prepare appropriate additional terms and conditions for annual contracts as needed. A record of subrecipient status and applicable documentation will be kept on file in the OSP. Otherwise this information will be kept confidential. The CAT will be completed by the Office of Sponsored Programs (OSP) Director of Post-Award Services or a designee who will work with the PI and UVU accountants to obtain the necessary data and make a determination of the risk status of a subawardee. For those years when the CAT is required by this procedure, the assessment will be completed prior to issuance of a new subaward agreement by the OSP. Any change in risk status of a subawardee will be communicated to the appropriate PI, Department Chair, and/or Dean at that time so that subsequent subaward agreements can be modified as necessary prior to the issuance of a new contract, or the contractual relationship can be terminated if necessary.

RECORDKEEPING

Documentation of project activities, services, results, and expenditures is essential to good award management. The Principal Investigator is considered to be the keeper of all records, even once the grant project has ended. All activities and expenditures during the grant are considered records or documentation of the project. Accurate and complete records are critical for demonstrating performance and project success, and for completing project reports and evaluations. Thorough documentation of a grant project will substantiate exactly what was done, when and how it was done, and how much money it cost. Accurate and complete records are a must. In the evaluation of the project from the funding source, these records will support the University in the services provided within the grant project.

As the Principal Investigator, you will want to establish a recordkeeping system that addresses, at a minimum, the establishment of electronic databases; the physical location and organization of electronic and paper files; a process to ensure the consistency and accuracy of electronic and paper files; and a method to document progress.

PROJECT REPORTS

Performance reporting and project evaluation are vital aspects of the implementation process. The success of your project will ultimately be judged by the project outcomes as demonstrated in the evaluation. Comprehensive grants frequently require the establishment of tracking of cohorts or other data collection activities. Many proposals typically include detailed evaluation plans which are used to identify the data elements that must be collected and the methods used to measure results. Having established baseline data and comprehensive assessment instruments at the beginning of the grant will make life easier as you evaluate the project.

The award notification typically includes a schedule for any programmatic and financial reports that must be submitted, and the dates the reports will be due. Depending on the funding agency, reports may be required monthly, quarterly, or annually. Most awards will require a final report summarizing the outcomes of the project. Programmatic and performance reports are the

responsibility of the Principal Investigator and should reflect the progress made in accomplishing the project objectives. Progress should emphasize results or outcomes, not process. Outcomes focus on the measurable results of the project activities; the process describes the activities that were implemented. During the new award orientation, the Director of Post-Award Services will review the required reports and establish due dates for all reports. The internal review/approval process and submission of programmatic reports are facilitated through the Director of Post-Award Services

All financial reports for the project will be completed by the Grants Accounting Office. The Grants Accounting Office must have complete records of project expenditures and documentation of matching or cost-share for the project to accurately complete reports. Any request for financial information from the funding agency should be sent directly to the Grants Accounting Office. A copy of a final financial report must be sent to the Director of Post-Award Services for OSP records.

CLOSING OUT GRANT PROJECTS

The closeout of a grant project is just as important as starting one. In many cases, how close-out procedures are handled, such as timely submission of final reports and the quality of the reports, can have a direct effect on the chances for future funding. Four main areas of management require particular attention at the close of a funded project: budget, personnel, record retention, and final reports. The closeout process should begin at least six months before the end of the grant. The closeout process is tracked using the ERA Software System platform called “SmartGrant”. Smartgrant allows the Post-Award Team to track the performance period of the award and associated required deliverables. This system is used in conjunction with Banner to track the financial expenditures of the awards.

BUDGET

Consult with the Grants Accounting Office to review the final budget to ensure there is a plan for final expenditures. Goods and services must be received before the end of the award performance period. The Banner system accounts will be closed soon after the grant’s ending date therefore, no additional expenses can be made against the grant account. Avoid making unusual expenditures at the end of the project. In addition, purchasing supplies or equipment late in the grant can be viewed unfavorably as it brings to question the legitimate need for the purchase for achieving project activities. Changes in the budget must be communicated with the Grants Accounting Office and the Director of Post-Award Services to ensure proper use of funds and documentation.

All items purchased with grant funds must be inventoried and documented. Consult with Property Management to make arrangements for appropriate transfer, removal, or reassignment of office equipment.

PERSONNEL

Consult Human Resources to complete termination paperwork for all sponsored-funded staff. You will need to complete the necessary payroll changes and ePAFs for positions that will be sustained and built into the University’s budget or other allocable indexes. All ePAFS for G indexes must have either the Post-Award Accountant or the Director of Post-Award Services listed as the optional approver/ reviewer.

RECORD RETENTION

During the closeout process, grant files should be reviewed to ensure that all documents such as personnel, purchase orders, requisitions, and budgets are included in the records. You will need to determine a secure location for paper files. For grants with multiple files, organize and label boxes to properly store the files. Clearly label the outside of the box to indicate: (1) Box number (e.g., 1 of 20, 2 of 20); (2) Funding agency and program; (3) Grant year; and (4) Destroy date. Submit an inventory list of boxes and their contents, in addition to the exact physical location of the boxes to the Director of Post-Award Services. For electronic records, please include the link or path to the shared drive file location of the stored information.

The terms of the grant will stipulate the length of time for which grant records must be maintained. According to Federal regulations, records for Federal grants must be retained until three years after the due date of the annual financial report for each year of the grant, however, the University maintains all financial records for seven years per State requirements. As a result, the most 15 restrictive rule applies. Please note that the grant award and terms and conditions may stipulate a longer retention period.

FINAL REPORTS

Sponsored programs typically require a final programmatic report from the Principal Investigator. This report will include a detailed description of the work performed, progress made, suggestions for future areas of need or involvement, and any related publications that resulted from the grant activity. Most funding sources have specific guidelines for the preparation and submission of the final report. Final programmatic reports are usually due up to three months after the grant ends. The Director of Post-Award Services will assist you in submitting and filing final reports on time. The internal review/approval process and submission of final reports are coordinated through the OSP.

Financial Reports

The Grants Accounting Office will complete all final financial reports within the required timeframes and with the appropriate forms. The Grants Accounting Office will ensure that the budget is at $0, and all funds are expended completely and appropriately.

AUDITS

Each year, UVU's records are audited by the State of Utah. As an internal process, our internal auditor may elect to review the project for compliance. Funding agencies also maintain the right to audit grant records. All financial records must be maintained to facilitate any audit(s) that may include a review of the project. In the event of a funding agency audit, the OSP will lead efforts to prepare for and respond to audit inquiries. The Principal Investigator must contact the OSP immediately after receiving verbal or written communication from the funding agency regarding a site visit, program review, or audit.

Audit findings can result in cost disallowances and require organizations to make repayments to the funding agency. The most common audit findings include: (1) lack of personnel services records (i.e. time effort reporting) to support salary costs charged to awards; (2) lack of consulting agreements and invoices to support that services were related to the award, (3) amounts were expended in unapproved or other cost categories without required prior written approval from the funding agency; and (4) adequate supporting documentation was not provided for match claimed.

Financial Audits

The Grants Accounting Office serves as the keeper of financial records for all grants for the University. Any updated budgets or budget revisions should be forwarded to OSP for reference and accurate grant oversight. All financial audits are coordinated with the Grants Accounting Office. In the event of a financial audit, the Grants Accounting Office (with the Director of Post-Award Services) will work with external auditors to supply the requested information, explain procedures, and answering fiscal questions.