Reporting and Notices to Sponsors
Reporting on the progress of a project is a responsibility that is shared between Principal Investigators / Project Directors (PI/PD) and their institution. In some cases (e.g. NSF), SPaRC can only view reports submitted by the PI/PD and the status of pending reports. In others (e.g. NIH), SPaRC is required, as organizational representative, to certify the accuracy of reports prepared by the PI/PD. In either case, if you anticipate any unavoidable delays in reporting, please notify SPaRC well in advance of the deadline.
The new Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards spell out, in 2 CFR 200.308, several circumstances requiring preapproval by the Federal awarding agency. There are other circumstances wherein agencies are given the latitude to waive pre-approval requirements, but even in many such cases, institutions are required to furnish timely notification to the awarding agency. PIs/PDs should contact SPaRC as soon as possible whenever they anticipate the possibility of one or more of the following:
- Change in project scope
- Change in key personnel
- Temporary disengagement or reduction in effort by a PI/PD or Co-PI/PD
- Budget changes, especially any relating to Participant Support Costs
- Changes in the number, scope, or amount of subawards/subcontracts
- Difficulty meeting mandatory or voluntarily committed cost-sharing
- Needing to spend money before the official start date of an award
- No-cost extensions
Such notifications may be sent via e-mail to the Director of SPaRC, or through the SmartGrant grants management system. Within SmartGrant, budget revision requests may be initiated by the PI/PD, an authorized administrator for a grant, or by the Director of Sponsored Programs and Research Compliance. Revision requests that result in either a net increase or net decrease of sponsored funds are not accepted by the system, and all requests must be accompanied by a narrative justification. Prior to implementation, all requests must be approved by the Director of SPaRC, who has the option of routing the request for prior review to the Assistant Director of Accounting, the Controller, or any other institutional administrator with relevant knowledge and expertise. Prior to approval, the Director of SPaRC consults the relevant Terms and Conditions of the award, which are referenced in the SmartGrant award record, to determine if the requested revision requires sponsoring agency approval. If so, the SPaRC prepares the request according to agency instructions, and further action in SmartGrant is withheld pending the agency response.
A budget revision would be denied if:
- the requested revision includes costs that are not reasonable, allowable, or allocable to the award;
- the requested revision is inconsistent with the applicable cost principles (e.g. Circular A-21 for Federal awards from prior to December 26, 2014, or the OMB Uniform Guidance for those thereafter);
- the requested revision is inconsistent with applicable institutional policies and procedures (e.g. compensation policies, or the institutional travel policy);
- the requested revision requires prior sponsoring agency approval, and such approval is not given;
- or the requested revision results in a budget that is inconsistent with the scope and objectives of the project as described in the proposal.
Once a budget revision has been approved by all necessary parties, the revision is posted to the award record in SmartGrant, and a copy of the revised budget is sent to the Assistant Director of Accounting for any necessary updates to the accounting system.