Project Implementation

(POST-AWARD)

Notification of a new award is generally sent from the funding agency to the Office of Grants and Contracts (OGC), which will then notify the PI and the ERB.  Sometimes the award notification will be sent directly to the PI.  When this happens, the PI should immediately inform the ERB.  Following award notification, the ERB fiscal personnel will enter information into appropriate College databases so that progress on carrying out responsibilities can be tracked.  The database information is also used to generate reports on research in the College.

Formal awards are entered into by the Regents of New Mexico State University, who accept such awards for designated purposes. There is a shared responsibility between the faculty and the University in accepting funds and carrying out the program for which the funds are awarded. The University designates the faculty member as the PI on a project, with the responsibility to act as an agent for the University in discharging the obligations associated with an award.

Project administration may be divided into two categories–technical and fiscal. Responsibility for these aspects of a project lies with the PI, the cognizant Department Head, and the ERB Director. If the technical quality of a project is not acceptable to the sponsor, it is the responsibility of the PI and Department Head to resolve the difficulty as promptly as possible. Regarding fiscal matters, it is the responsibility of the PI, with assistance provided by the ERB, to expend funds according to agency guidelines.

Account Set-Up and Expenditure of Funds

A signed agreement with the sponsor must be received before a new index can be set up for use by the PI.  ERB personnel create the necessary internal documents to initiate this process.  Once OGC has reviewed the packet and found everything to be in compliance with the award, it is sent to SPA, where a fund is created.  The packet then goes to the Financial Information Process, where an index is established.  From this point on, the PI can use the funds for any project-related charges in agreement with agency guidelines, State regulations, and/or Federal guidelines.  ERB staff will assist with making sure that the proper paperwork is accomplished to allow for prompt establishment of the index.

An ERB fiscal staff member will be assigned to work with each PI regarding budgetary aspects of the project.  All expenditures will be checked according to agency, Federal, State, and University guidelines.  A PI needs to ensure that the expenditure of funds is appropriate.  If the PI spends more than is budgeted for the project or spends project funds for an expense that is not allowable, one-half of the deficit will be covered from a return of IDC funds to the Department and one-half will be covered from IDC funds returned to the College, a situation that is frowned upon.  In some cases, inappropriate expenditures will have to be covered by the PI’s own funds.  Deficits cannot be transferred to other restricted research accounts, but they can be charged to an unrestricted account.  ERB fiscal personnel are always available to answer any questions about allowability of expenses to help avoid irreparable mistakes that redound to the PI.

For further information on Business Office policies, visit http://www.nmsu.edu/~boffice/; for access to forms related to Business and Finance, visit http://www.nmsu.edu/~boffice/forms/; see also http://research.nmsu.edu/ogc.html for forms and definitions in OGC.  For more general information, visit http://manual.nmsu.edu/ for the NMSU policy manual and http://www.whitehouse.gov/omb/ for the OMB circulars A-110, A-21, and A-133.

Budget Revisions

In collaboration with ERB personnel, the PI should carefully pre-plan expenditures to keep budget revisions to a minimum.  If it becomes necessary to revise a budget, the PI should contact the ERB to discuss the appropriateness of a budget revision request prior to its submittal.
Generally, if agency approval is required for a budget revision, the PI must write a letter to the agency requesting a budget revision.  The letter should indicate the amount to be transferred, the budget category from which the funds will be transferred, and the budget category to which the funds will be moved, with a clear and sound justification for the change.  The request should go through the ERB, but the OGC officer is the only person with authority to negotiate and formally change the provisions of a grant or contact.  Each agency uses different formats to request budget revisions, thus it will be necessary for the PI to contact the program officer for specific instructions before preparing the request.

Correction of Errors in Charges to Project Indexes

When an error occurs in charges made to an index, correction is made through use of a Journal Voucher.  With regard to labor redistributions, a transfer of charges must be processed within 90 days of the date of the initial charge.  The ERB will not approve the transfer of charges after a project has terminated unless justified by the PI and approved by the ERB Director.

Hiring Process

It is essential that no hires for a project are initiated until an index has been created by Financial Information Processing (FIP) and that no salary level is promised until HR sends an official Permission to Offer notice.  Once the award is official, the PI should complete a Position Description Questionnaire (PDQ) and attach the desired candidate’s vita/resume.  With approval to proceed from Human Resources (HR), the PI’s administrative assistant needs to contact the Budget Office to create a budget and salary line.  Once this step is completed, the administrative assistant can initiate the hiring process by completing the online Staffing Authorization Form.  With approval of the Authorization, HR will send the Permission to Offer and once the desired candidate accepts the offer, the administrative assistant can fill in and submit the Hiring Confirmation, which includes employment dates.   Please note that the start date cannot precede the date of the Hiring Confirmation.  It should be noted that in each step of the HR process, documents are routed electronically to the cognizant department head and back to ERB for approval, prior to reaching HR for final approval.

In case of dire need, an employee can be hired (after the index has been created) through the Emergency Hire process, which is valid for one year.  In the first six months of this year, the PI should initiate the search process (with the same PDQ  used in the emergency hire) to create a permanent position.

Invoicing

Invoicing is carried out by Sponsored Programs Accounting (SPA) and may sometimes lag project expenditures by a significant time period.  While having no role in billing, ERB personnel can assist PIs in tracking what services have been billed or why invoices submitted have not been paid.

Financial Close-Out

Three months prior to termination, a project will be closely reviewed by ERB fiscal personnel to assure that funds are being spent out appropriately.  The ERB may contact the PI to ascertain how remaining funds will be spent or to address outstanding invoices that may be problematic.

It is the responsibility of the PI to inform the ERB fiscal personnel of any special cost requirements during the last three months of project operation so that such costs can be taken into consideration.  In addition, PIs must ensure that leave accrued during the life of the project is taken during the period of project execution as there is no mechanism to set aside funds for accrued leave taken after the end of the grant or contract.

Technical or Progress Reports

It is the responsibility of the PI to provide technical or progress reports to the funding agency according to the timeline provided by the agency.  Most funding agencies withhold final payment and will not approve subsequent awards to a PI if the final report is not received.   The PI should provide the ERB a copy of any reports (including the transmittal letters) submitted to the funding agency.  The transmittal letters will be placed in project files as part of the final close-out process.

Allocation of Indirect Costs (IDC)

Of the total Indirect Costs received on a given project, the Central Administration of the University retains 51.8% for distribution to the Budget Office (for reallocation to central offices and to support strategic efforts), the Library, OFS (for maintenance of buildings), and the Provost.  The remaining amount, 49.2% is sent to the appropriate College or administering office.  In the College of Education, the 49.2% share is distributed to the ERB (75%) and the appropriate Department (25%).  If the IDC rate is 10% or greater, the ERB share is reduced to 70% and the Department share is reduced to 20% so that 10% can be distributed to the PI.  Thus, it is to the PI’s advantage to request the highest IDC rate possible when developing a proposal. The ERB distributes IDC within the college on a quarterly basis.

Should there be leftover funds on a fixed-price award and, consequently, unrecovered IDC, NMSU’s Central Administration retains the full amount of IDC that would have been assessed on the grant and gives the college the remaining IDC funds.