The technical requirements and the day-to-day administration, as well as financial management, of the project are the responsibility of the Principal Investigator, under the supervision of the Department Administrator, Department Chairman, and ACHRI.
PLEASE SEE SECTION 2.0 FOR COMPLETE LISTING OF THE PRINCIPAL INVESTIGATOR’S RESPONSIBILITIES
Once an account number has been assigned to the awarded project, the approved budget is setup in the eRequest system by the Research Account Administrator. The eRequest system enables the PI and staff to manage the funds on a daily basis. Procurement for supplies, travel, equipment, and other expenses is accomodated by generating requests in eRequest which electronically routes the requests to the required approvers. When requests are created, the funds in the account are encumbered (held) to prevent overspending. The encumbrance is removed once the requests are actually expensed to the account which occurs when ACH Accounts Payable issues payment for invoices and reimbursements.
The approved request will route to Purchasing when supplies or equipment (goods) are being purchased, and a purchase order will be assigned. Upon receipt of the items and invoice, ACH Accounts Payable will process for payment.
For travel reimbursement and purchased services, the PI/staff will copy the approved request and forward to ACH Accounting for payment.
100 Days prior to the end of the budget/project period, the PI will receive a notice that the account will close and an account review will be scheduled by the Research Account Administrator. The PI and their business person should plan to attend the review. Representatives from ACHRI, ACH Accounting and UAMS Accounting will be present to address all questions and concerns regarding the close of the award budget/project period.
The federal government and many non-federal sponsors require that projects be closed within ninety (90) days of the termination date of an award. In fact, many sponsors refuse to issue new awards if existing awards are not properly closed. Expenditures and corrections submitted after the 90 days cannot be approved and will be returned to the submitting department.
Closing Procedures
PIs and administrators must monitor each account to be sure that erroneous charges, unallowable charges, and over-expenditures are removed from the sponsored project. In order to close properly, an account's total expenditures must match its total income. If expenditures are less than income, excess income must be returned to the sponsor (if the sponsor has given the money up front). Even more important, sponsors will not reimburse ACHRI for charges that exceed the award amount. In certain instances, the PI may be asked to reimburse ACHRI from departmental funds should over-expenditures occur.
Principal Investigator Termination Checklist
If you are the PI on any current or ongoing awards and you are leaving employment at UAMS or ACH, you will need to take steps to address several issues.
Grant Closeout:
If the grant is to remain at ACHRI, a new PI must be identified and the sponsoring agency must approve this person. Typically, this is accomplished with a letter requesting the change and a copy of the new PI's Curriculum Vitae (CV). A signature from the authorized representative for ACHRI may be required as well depending on the sponsoring agency requirements.
If you are transferring to another institution and desiring to move grant(s) to the new institution, you will need to contact your department head for approval first and then the ACHRI grants office to identify the specific transfer requirements for your project's sponsor. Most frequently on federal awards, a final financial report will need to be submitted that reflects the unexpended balance that could be moved to your new institution.
Closing Procedures:
Occasionally a fixed price contract may have an unexpected balance remaining at the end date. IF the deliverables are complete and submitted to the sponsor, in certain circumstances it will be necessary to transfer the remaining balance to an unrestricted fund. Prior to the transfer of any residual balance, the fully federally negotiated research rate will be collected by ACHRI. As an example, for a fixed price contract with a remaining balance of $5,000 X 38% equals $1900 which will be collected by ACHRI, so the balance to be transferred to the unrestricted area is $3100.
Equipment:
If you are transferring to a new institution and you wish to take any equipment purchased with grant funding during your employment at UAMS/ACH, you must prepare a listing to be presented to your department head for approval. Any release of equipment will be at the discretion of the department head. A copy of the approved list will need to be supplied to the Post Award Office,Leslie Montgomery, so that accurate inventory records can be maintained and the ACHRI property control tags can be removed. For government-owned equipment, the underlying grant/contract document will provide the disposition instructions to follow.
Final Reports and Deliverables:
As the PI on a grant/contract, it is your responsibility to ensure that the final technical report and any other deliverables as required under the contract documents are delivered to the sponsor within the allowable time frame and prior to your departure from UAMS/ACH.
Cost transfers include any shifts of expense to a project account and/or to a subcontract account under a grant or contract. They can occur via a journal request, time and effort changes, or a retroactive salary request.
Institutions receiving federal contracts and grants are subject to audit disallowances in the area of cost transfers. Late cost transfers made from an over-expended account to an under-expended account suggest poor planning and management. External auditors will assume they have been made simply to cover the over-expenditure or to use up remaining funds. An explanation of the transfer is required on all forms that involve the ACHRI account numbers.
Appropriate Types of Cost Transfers:
Federal regulations recognize three general circumstances under which cost transfers may be appropriate. In all cases, the transfers must be timely, within ninety days of the original transaction, and in all cases, expenditure correction forms are necessary:
A. To correct clerical errors in the original charges;
B. To reflect legitimate re-budgeting as a result of a change from the initial work plan; and
C. To reallocate resources between accounts that support closely related work for reasons other than to cover over-expenditure or to spend out remaining funds. "Relatedness of sponsored projects" must have been established in advance with the sponsoring agency.
Federal guidelines also specify the type of written documentation required to justify these transfers.
Appropriate transfers must be accompanied by a written explanation of:
- When and how the original charge occurred.
- Justification for the new charge.
- Back-up documentation.
These corrections should be discussed with the ACHRI grants office, Leslie Montgomery, before any budget adjustments are made.
Pre-audit of expenses prevents costs that are not in compliance with federal regulations from being charged to sponsored projects. Submitted expenses are reviewed to determine the allowability of a specific charge based on current budget and expenditure information. If, after review, the charge is determined to be allowable, the invoice is approved for payment. If, however, the charge is considered unallowable, it will be returned to the department with an explanation.
If expenditure is not budgeted, the proper approvals through the ACHRI pre-award office or from the sponsor should be obtained prior to incurring the charge(s).
Before re-budgeting, make sure you are aware of any sponsor requirements that apply to your award. You may find this information in the award document or contract and/or you may call the ACHRI Pre-Award office, to get the answer.
Re-budgeting requires careful attention. Although it may seem easy to shift an expense from one category to another, the differences between line items that allow overhead costs and those that do not create the need for a specific formula adjustment to the F&A collection. Furthermore, if you are re-budgeting to or from a restricted class, you may need departmental or sponsor approval.
Arkansas
Children's Hospital Research Institute
1120 Marshall Street
Little
Rock, AR 72202
(501) 364-7373
Fax (501) 364-2705