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Policy and Procedure Statements

UPPS 02.02.02 - Sponsored Programs - Post Award

Sponsored Programs - Post Award

UPPS No. 02.02.02
Issue No. 8
Effective Date: 12/06/2024
Next Review Date: 7/01/2029 (E5Y)
Sr. Reviewer: Senior Director of Sponsored Programs

POLICY STATEMENT

Texas State University is committed to managing all external funds received for the purpose of research and ensuring governmental rules and regulations are applied appropriately.

  1. SCOPE

    1. The purpose of this policy is to provide general guidelines for the administration of sponsored programs. Post-Award Support Services in the Office of Sponsored Programs (OSP) has the authority and responsibility for promulgating policies and procedures related to post-award activities for sponsored programs.

  2. DEFINITIONS

    1. Acceptance of Awards – written approval from Post Award or other Texas State University-authorized contracting official constitutes acceptance of awards. Generally, this takes the form of a written contract.

    2. Award Document – the agreement processed by the sponsor and sent to the university specifying the terms under which the program will be conducted.

    3. Externally Funded Contract – an agreement between Texas State and another entity or sponsor to provide an economic benefit for which compensation is paid to the university. Both the university and sponsor receive benefit from the contractual relationship. There is a written agreement, often negotiated, between the university and sponsor, which is enforceable by law, and creates a quid pro quo relationship.

    4. Grant – funding awarded to the university as an additional resource to support instruction, research, or public service. Grants are usually given to accomplish a specific purpose.

    5. Principal Investigator (PI) – the individual responsible for the research or other activity described in the proposal for a sponsored program.

    6. Sponsor – the governmental agency, commercial, or non-profit organization that makes an award directly to the university.

    7. Sponsored Programs – externally funded grants and contracts as defined within this policy.

    8. Sub-award and Subcontract – a contractual agreement with an individual or entity outside of the university to perform a significant portion of the scope of work of the award. To qualify as a sub-awardee or subcontractor, the work done by the sub-awardee or subcontractor must be integral to the completion of the scope of work of the award (made to the university).

  3. RELATED POLICIES AND PROCEDURES

    1. Refer to UPPS No. 05.02.02, Texas State Purchasing Policy, for purchasing guidelines.

    2. Refer to UPPS No. 03.04.10, Contracts and Agreements, for general guidelines in obtaining the services of consultants or lecturers.

    3. Procurement Cards (P-Cards) – The use of P-Cards is for incidental supply purchases only. Declining cards (D-Cards) are an option where PIs preload the card with funding to spend and can also be used for research purchases such as human subjects’ incentives (see UPPS No. 02.02.06, Research Cash Advances). The amount budgeted for supplies and materials in the sponsor-approved budget will determine the limits established on the P-Cards. Refer to university P-Card policies and procedures, available online.

    4. Contracts for the purchase of goods or services are to be processed in accordance with UPPS No. 03.04.10, Contracts and Agreements, and UPPS No. 03.04.02, Contracting Authority.

    5. Interagency cooperation contracts for the purchase of goods or services from another state agency are to be processed in accordance with UPPS No. 03.04.10, Contracts and Agreements.

    6. The establishment of off-campus leases for space are to be in accordance with UPPS No. 08.01.16, Facilities Leases.

  4. TRAVEL

    1. Refer to the Texas State Travel Office website for university guidelines regarding travel.

  5. PROCEDURES FOR AWARD ACCEPTANCE

    1. Application or Award Acceptance – A sponsored program is not operational until the university has officially accepted it. PIs are generally not authorized to enter into any agreements on behalf of the university. (See UPPS No. 03.04.02, Contracting Authority, and UPPS No. 03.04.10, Contracts and Agreements.)

    2. PIs should not spend funds from a program until their university accounts are established. Funds expended without authorization may result in personal liability for the PI.

    3. An account number may be established, on a provisional basis, prior to written confirmation of the award if Post Award deems that an award is imminent. A written confirmation from the PI, their department chair, school director, or dean identifying another account to be used if funding is not available must be received by Post Award prior to establishment of the account.

    4. Other Approvals – Post Award will not establish an account for expenditure purposes for any sponsored program that has pending Institutional Review Board or Institutional Animal Care and Use Committee protocol approvals. In addition, accounts will not be established for sponsored programs that have intellectual property agreements or conflict of interest disclosures that require prior approval by the vice president for Research, or designee.

  6. SUB-AWARD AND SUBCONTRACT PROCEDURES

    1. A documented contractual agreement is required for sub-awards and subcontracts when an individual or entity outside the university is to perform a significant portion of the scope of the work under a sponsored program agreement awarded to the university.

    2. Post Award prepares and executes the contractual agreements for all subawards and subcontracts. The PI is responsible for consulting with Post Award to initiate and renew such agreements.

    3. There are certain monitoring controls the PI must undertake to ensure subcontractor compliance with agreement terms and conditions. The OSP Website contains more information on subcontractor monitoring requirements.

  7. BUDGETARY CONTROLS

    1. The PI will work with Post Award and will follow sponsor guidelines and commitments. Budget revisions must follow guidelines from the sponsor. Budget revisions are subject to university approval.

    2. If a sponsored program account is over-expended or costs are disallowed, the PI has primary responsibility for taking corrective action. The PI has 10 days from date of notification by the sponsor or Post Award to take corrective action. If the PI does not respond to Post Award in writing within that timeframe, Post Award will identify an account for reimbursement and process the necessary transfer. Such accounts may include earned facilities and administration (indirect cost) accounts in the following order: PI, chair, director, dean, and vice president.

    3. It shall be the responsibility of the PI to ensure that all Personnel Change Request (PCR) appointments to a sponsored program account are maintained within date and budget limitations. If a sponsored program account is paying salary, and no PCR is processed by the department causing the individual’s salary to post to the salary clearing fund (8999999999) for any reason (date exceeded, budget exceeded, etc.), Post Award will notify the PI and administrator of record (as found in SAP master data) of the issue. The PI shall have three business days from the date of the written notice to prepare a corrected PCR and submit to Post Award for processing. If the PI fails to take this action, Post Award shall have the authority to move expenses to the earned indirect cost accounts in the following order: PI, chair or school director, dean, or vice president.

  8. HUMAN RESOURCES PROCEDURES

    1. All part- and full-time staff positions on sponsored programs are subject to the same hiring procedures as all other university positions. Refer to UPPS No. 04.04.03, Staff Employment for procedures on hiring personnel.

    2. Costs of personnel are allowable on research agreements to the extent supported by actual effort performed on the project and approved in the award budget.

    3. Staff and graduate students are appointed through the Human Resources Office and paid by PCR. The PI, account manager, or their staff is responsible for the generation of the PCR and acquiring the appropriate approvals. Post Award reviews all PCRs on sponsored programs.

    4. Refer to UPPS No. 04.04.12, Pay Above Base Annual Salary for Staff, regarding compensation in excess of base salary.

    5. Refer to UPPS No. 04.04.11, University Classification and Compensation, for guidelines for salary adjustments. The sponsor must fund salary adjustments for personnel being paid either part- or full-time from a research contract. Therefore, the PI should include estimated annual salary increases in the sponsored program proposal or application.

      PIs should review requested salary increases for consistency with those offered to other university personnel. Any salary adjustments proposed by the sponsored agreement must adhere to the guidelines outlined in the current University Pay Plan. The same rate of salary increase will be available for employees paid from sponsored program accounts as for other university employees, subject to funding availability.

    6. Retroactive Salary Transfers – From time to time, a PI, account manager, or their staff may retroactively transfer salary from one grant or university account to a different grant or university account. Transfers of retroactive salary shall be processed via PCR as soon as it is determined a change is needed. Salary transfers should not be processed after 90 days have passed, since the pay was recorded in the university’s administrative accounting system. Detail documentation and support must be attached with the PCR for proper evaluation.

  9. REPORTING PROCEDURE

    1. Technical, Program, and Financial Reporting – Terms of the sponsored program generally require the submission of a written final technical, financial, or progress report to the sponsor within a specified period of time. The sponsor may require more frequent or other types of reporting. The PI is responsible for the preparation and submission of technical reports and other required deliverables. OSP is responsible for preparing financial reports for sponsors. The PI must comply with all of the terms and conditions imposed by the sponsor.

  10. RESPONSIBILITIES

    1. Post Award is dedicated to providing administrative support to project managers of externally funded programs, while maintaining the fiscal integrity of the university. The primary responsibilities of the office include the following:

      1. reviewing and signing contracts for sponsored agreements (refer to UPPS No. 03.04.02, Contracting Authority);

      2. establishing, maintaining, and closing sponsored program accounts;

      3. interpreting and enforcing sponsor, university, and other administrative policies;

      4. ensuring that expenditures are monitored in accordance with both sponsor and university policies and procedures for allowability (e.g., reasonable and allocable, as well as consistent, necessary, and permissible), including timely review of operating reports;

      5. preparing and monitor sub-award agreements and subcontracts;

      6. working with faculty and staff to provide accurate and timely financial information;

      7. preparing financial reports to sponsors;

      8. carrying out cash management responsibilities associated with the funding of certain sponsored projects (the General Accounting Office maintains responsibility for all others);

      9. acting as a liaison with other university administrative support units, sponsors, and auditors;

      10. providing advice on pre- and post-award business and financial matters;

      11. reviewing and submitting invoice to sponsors;

      12. approving changes in contractual obligations under the sponsored program agreement; and

      13. reporting non-compliance matters to university management for action and possible discipline.

    2. The PI has a fiduciary responsibility for the proper fiscal management and conduct of the project. The responsibilities of the PI include the following:

      1. serving as the account manager of the sponsored program (refer to UPPS No. 03.01.09, Fiscal Responsibilities of Account Managers at Texas State; UPPS No. 03.01.05, University Income Recognition and Associated Cash-Handling Procedures; and UPPS No. 02.02.01, Applying for Sponsored Programs);

      2. assuring compliance with all the terms and conditions imposed by the sponsor;

      3. ensuring that project funds are managed efficiently and effectively within approved budgets;

      4. preparing and submitting technical reports and any other required deliverables by sponsor deadlines;

      5. ensuring all expenditures submitted to a sponsored program account are reasonable, allocable, and allowable. Recording and documenting expenditures made for any matching (cost share) commitments included in the project agreement;

        NOTE: The PI must assure that matching funds comply with sponsor guidelines.

      6. notifying Post Award of any needed program changes, including contract amendments, so that Post Award can obtain sponsor approval; and

      7. consulting with Post Award to initiate or revise sub-awards and subcontracts.

    3. Department chairs, school directors, deans, and vice presidents are responsible for monitoring the work performed under sponsored programs to assure compliance. This includes performing adequate reviews to assure that Post Award and the PIs perform their duties and cost sharing and matching are managed (per Sections 10.01 and 10.02).

    4. All administrators in the chain of command for a PI share the responsibility for helping to ensure overall sponsored program compliance. The university is ultimately legally and financially responsible and accountable to the sponsor for the performance of the funded activity and the proper use of funds. The full cooperation and vigilance of the PI is essential to assure that the university accomplishes its stewardship role.

  11. REVIEWERS OF THIS UPPS

    1. Reviewers of this UPPS include the following:

      PositionDate
      Senior Director of Sponsored ProgramsJuly 1 E5Y
      Assistant Vice President for ResearchJuly 1 E5Y
      Associate Vice President for Financial ServicesJuly 1 E5Y
      Vice President for ResearchJuly 1 E5Y

  12. CERTIFICATION STATEMENT

    This UPPS has been approved by the following individuals in their official capacities and represents Texas State policy and procedure from the date of this document until superseded.

    Senior Director of Sponsored Programs

    Assistant Vice President for Research; senior reviewer

    Vice President for Research

    President