Subcontractors, Consultants and Vendors: So Many Choices, Still So Confusing.

hire.outsource image

There are more proposals to submit to agencies than ever before – and the criteria for competitiveness includes an institution’s ability to collaborate – not only within its walls but with investigators working on related research at other institutions.

The selection of the proper agreement type for a collaborator during the proposal phase should happen as early as possible, with the investigator working with the research administrator and the collaborator to evaluate the proposal mechanism and the statement of work. A set of questions help evaluate the best agreement for the collaboration.

What criteria determine the type of agreement for a sponsored project?

1. What is the service, function or activity they will perform (with some specificity).

A subcontractor or consultant will typically have a more detailed scope of work than a vendor, which has a very specific task to perform. A subcontractor and consultant perform work which relates to the aims of the award, which have milestones and reports attached, and often require analysis. However, the outcomes of the work are not predetermined. A vendor’s work is determined by its regular course of business as it is contracted to perform a service on behalf of the award, and it either performs the service, or it does not.

2. Under what time frame will they perform it?

Accordingly, the time frames for the agreements will match the types of work performed. A vendor is usually engaged until it finishes the work performed.

3. Will they be using the facilities of an institution, or their own facilities?

Subcontractors and vendors use the facilities of their institutions; consultants use their own facilities, and not the facilities of their institutions (unless they are a small business).

4. Who will the check be made out to (who will receive the 1099)?

A subcontractor and vendor will have payments made to an institution. A consultant is almost always an individual, but can be a business. In the event that a consultant is a business, this arrangement should be reviewed periodically to ensure that the agreement should not be revised to become a subcontract in subsequent years. (Yearly consulting agreements should be considered.)

5. Does the contractor expect to have publication rights?

Only if the contractor is a subcontractor. A consultant does not typically receive publication rights.

6. Will the work of the contractor affect the direction of the science in some way?

Only if the contractor is a subcontractor. A consultant does not typically have the ability to influence the direction of the science, as the role of a consultant is to produce a work product under the direction of the PI but does not have a named scientific role. If the individual is to direct the science, they should work under the auspices of their academic institution and contribute based on their institutional based salary/effort.

7. Is the contractor working in a capacity with a level of independence?

A subcontractor or consultant, based on their named role on the project has the ability to function independently with oversight by the PI. A vendor cannot function independently. They have a scope of work that they need to complete under the direction of the PI by a specified time frame, and there is no room for deviation or independence.

8. Do the terms of the award flow down to the contractor?

The terms of the award flow down to the subcontractor and the consultant, but not the vendor. This may be a vital distinction when selecting a correct agreement type for a collaborator.

AFTER THE FACT AGREEMENTS – NOT A GOOD IDEA

I’m very appreciative, but often surprised when an investigator suggests setting up a subcontract after the fact to “save work” and time, because it seems too cumbersome to set it up during the proposal phase. In fact, setting up the subcontract, consultant or vendor agreement during the proposal phase is crucial – because at that time, F&A is being established based on the proposal budget. When the proposal is awarded, and F&A is set – any after the fact subcontracts or other agreements have to include F&A out of direct costs. This is a VERY painful budgetary impact that could have otherwise been avoided.

PREPARING THE REQUEST FOR THE COLLABORATOR

When the collaborator is a subcontractor, we have a standard package of materials that we send from our institution that we hope will make life easier for the research administrator we are working with, who will almost always be receiving the request (we ALL know this) later than we would like.

  • Northwestern’s subcontractor form (Financial Conflict of Interest Statement with standard SF424 info)
  • Draft Budget and Budget Justification
  • Draft Statement of Work

For a consultant, we provide a draft consultant letter, which states the hourly rate of pay, travel per diem, length of time work will be performed, nature of the work to be performed and support for the project. We also provide detailed instructions for completing our FCOI process for the proposal.

Common Question: Can a consultant on a proposal be an investigator at my institution?

If the work on a sponsored project is not related to an investigator’s regular work, and is not an ongoing assignment, it may be possible to justify a consulting agreement at your institution for an investigator who is also employed by your institution. However these agreements require prior institutional approval before they are proposed and should be done with proper planning. A PI cannot propose an investigator in the same department as a consultant.

Be a Spreadsheet Superhero!

h84236603 YOU CAN BE A SPREADSHEET SUPERHERO.

It’s the heart of every budget – the spreadsheet. How it is written and constructed sets the course, not only of the few weeks it takes to submit the proposal – but of the years it takes to manage the project when it is funded. The spreadsheet starts off innocently enough, as a draft that one or two people (usually the PI and the research administrator) work to edit as the proposal is constructed. Carefully planned and well constructed – this can be a time when decisions are made, and documented to set the life of the project off on the right course. Or…not.

CREATING CALM OR CHAOS IN GOTHAM CITY

It’s quite common to learn research administration from the inside out – that is, you join a project mid-stream, and pick up the documentation that a previous team generated for you to work with. That means that your success in helping to administer the research in a department or division depends on the communication that has been left for you by the previous RA, and the internal budgets you’re responsible to manage. It’s more than just written communication – it’s the budget spreadsheets that allow you to help guide your investigators to make decisions about how their projects will be managed in the coming project period.

IT’S A BIRD…IT’S A PLANE….IT’S….EXACTLY THE ANSWER I WAS LOOKING FOR

So how does one become a spreadsheet superhero? It requires some practice and dedication, and a commitment to consistency – knowing that you’ll be serving your investigators long after you leave your position and move on to your next job if you take on this alter ego.

ATTAINING A SPIDEY-SENSE FOR SPREADSHEET SUCCESS

1. Always use formulas and references when budgeting in Excel. Hard enter numbers only when absolutely necessary. Make your spreadsheets work for you, and your investigators.

2. Ask your colleagues for the best budget spreadsheets out there – and if one doesn’t exist (rest assured it does) create one. Find one that works best for your investigators’ applications and use it consistently. Time and date stamp it. Improve it as you use it for each application.

3. Budget based on institutional base salary. If you don’t know what institutional base salary is for your institution, find out. If your spreadsheet doesn’t start or takes you off course from the IBS at your institution, you will be managing cost-sharing on the award if it is awarded.

4. Try very hard to help your investigators to break the habit of doing their own budgets. You can draft them and let them play with the numbers. Many investigators forget elements of budgets – and others don’t understand why certain costs need to be included. In all cases, they need to focus on the science, and that’s why we’re there, to help with the administrative aspects of the application. It’s hard for them to depend on us. Try to help them learn to depend on you.

5. Check your math. Have a colleague review your budget and justification, just to make sure. These things are often developed very quickly and often under pressure. It’s easy to make transposition errors, etc. Have someone with fresh eyes who has had a bit more sleep take a look at your work.

6. Spend a lot of time on the budget justification. Flesh it out for the PI, to help explain the nature of each expense. Include an explanation of the calculations involved if there is a question about how the funds are to be spent.

7. Include the names of individuals working on the project in your budget spreadsheet – even if they are not included in the official proposal documents. Simple details like this are very helpful when administering salary on funded projects.

8. When creating budget spreadsheets, put yourself in the recipient’s shoes – what does the reviewer need to see? Present the budget with that in mind and keep it clean and tight. Present supporting information in sheets behind the summary page of the workbook, linking totals to the summary page. Crowding everything into one page dilutes the information you are providing and adds to the reviewer’s job. (It can also increase the chance of error and cost-sharing.)

9. Use your spreadsheets consistently – for applications, award management (clinical trial tracking, grants management, contract management, salary and effort management, and reporting to investigators). Create roll up reports to identify areas of concern (projected deficits) and manage no-cost extensions prior to them coming due.

10. Create a shared repository for this information for the investigators you work with, as well as the business administration team and central office staff you interact with. As you maintain these records, they will serve to document the active management of your investigators’ activities, help you manage their awards, and hand off their accounts easily to the next person who steps into your role. And that’s customer service!

It’s not easy to keep up with these types of records, especially when things get busy – but its harder not to – especially when there is a need for the information. Take the time to learn Excel well, and share your knowledge and time with your colleagues. Spend the time to develop the systems and processes to support your investigators and develop the spreadsheets that will serve you – and them well – now and far into the future.

How Many People Does It Take To Allocate An Expense To A Sponsored Project?

ideaWhen Your Office’s Cost Allocation Processes  Resemble the Punchline of that Familiar Joke, it’s Time to Take a Look at Your Decision Methods

We recently had a situation in our office where a question was raised about the method of allocating an allowable supply cost to a sponsored project. The supply cost was $30. The “answer” generated more than one week’s worth of discussion involving the time of eight employees in three different offices. In other words, more than $30 worth of F&A was spent on deciding whether or not it could or should be charged as a direct cost on the award. (It was direct charged, and it should have been, it was the right thing to do.)

You’ve Hammered The Nail Down. How Many More Times Do You Need To Hit It?

This is not a discussion about whether or not we want to be compliant – this is a discussion about the BEST way to be compliant. The reality is, that there is often MORE than one way to allocate costs in a compliant manner, and the fact of the matter is that we can allocate costs as effectively as possible, following all the rules and guidelines provided by the funding agency and OMB circulars – and an auditor can still request to remove the charge for a particular reason on an audit. (They may, or may not be successful.) At the end of the day, we need to realize that we are going to make the best decisions possible, according to policies, decide who is responsible for decision making, and move on. So how do we do this, and how can we avoid the black and white thinking that so often comes along with cost allocation processes – and makes the process so PAINFUL and time consuming?

A Starting Place for Understanding Cost Allocation: Three Questions

1. Who decides if the charge goes on the award, and who reviews/approves this decision?

It’s been my experience that the best cost allocation decisions are made at the department level – they are usually initiated by the investigator, and followed up on by a research administrator, who determines how best to allocate the cost to the award – and confirms this with the investigator. The RA might consult with a central office, but a central office role is usually to review and approve the charge once it is placed on the award, and that’s the appropriate role for the central office. It’s good to make sure we’re charging the award appropriately before we’ve touched it – but the local department knows more about the research and how the award is being conducted. The investigator also knows their program officer’s expectations, and grants management officer’s guidelines about how the award should be spent.

2. What information helps guide the decision making process?

The OMB circulars, the award documentation, and the agency guidance regarding allowable costs, as well as institutional policies and procedures regarding cost allocation. Whew! That’s a lot of information that is sometimes contradictory – so where do you start? The most specific guidance for the award pertains first.

3. What documentation supports the decision, and how is this documentation generated and maintained?

There is nothing WORSE than cost allocation processes that are not consistently followed – think A21. Following processes that document purchasing, and the allocation of costs on awards and document these costs consistently so that administrators can follow your thought processes are vital (everything from always using formulas in Excel spreadsheets to entering in justifications to every computer system that you use to execute financial transactions).

Fundamental Knowledge for Successful Cost Allocation

  • The research administrator needs to know the units for accepting costs (this sounds trivial and simple, but it really is quite important). Are costs to be allocated by project, lab, employee, etc?
  • Roles need to be maintained – it is surprising how often central office staff regularly allocate costs to account codes that are inappropriate or feel that they know best how to allocate costs, when they know little about the research itself or the cost item being allocated.
  • The consistency principle for A21 should be (in my opinion) maintained by research unit – similar types of research. Again, this is something that departments know better than central offices – allocation of expenses for wet labs is going to be different than allocation of expenses for dry labs, or clinical research labs. Explaining this to a central office accountant is important to ensure the correct allocation method for the sponsored research account.
  • Allowability and reasonableness are usually easier terms to work through, based on the award information.

When in Doubt – Double Check and Documentgroup-of-small-business-people

If you have a particularly unusual situation, work with your investigator to talk with your central office, and his or her grants management specialist about the question to receive approval. Document the decision if it is favorable. It’s still no guarantee – but it’s a good indication that it’s an allowable cost. Document all of the justification material and correspondence for future reference.

The Best Defense Is A Good Offense

As always, the investigator is always in the best position to support his or her cost allocations when the budget and budget justification are well developed in the proposal stage, and his or her progress reports, financial reports, and updates are well tracked and presented. Our cost allocation decisions should make sense, and be defensible when we are asked about them by our internal and external auditors. And it shouldn’t take a village to allocate the cost of a $30 item to a sponsored project – because there’s more work to be done!

The Pasteur Principle: Using Sponsored Research Best Practices to Prepare for Audits

While attending a conference is an important part of one’s career development, returning from one (and dealing with an overflowing email inbox and the ongoing demands of the workplace) is also part of the deal. Life doesn’t stop while we’re developing new skills – and the continuous requirement to improve, while preparation_mousetrapmeeting the needs of our current job requires the mastery of a micro-vascular surgeon, the decision making ability of a Fortune 500 CEO, and the time management skills of an air traffic controller at La Guardia. Diet Coke, anyone?

I thoroughly enjoyed the intellectual enterprise that was the NCURA Financial Research Administration Conference in New Orleans.  It’s the best conference they offer- hands down, so mark your calendar for next year’s event.

On Monday evening, I’m off to Milwaukee for the regional NCURA conference with my colleague Matt Irwin to discuss the management of clinical research faculty salaries using our salary and effort management tool. But before I do that, I thought I’d recap the presentation that Melody Delfosse and I gave in New Orleans (which is posted in the presentations section for anyone who is interested).

Catchy Title, Anyone?

Louis Pasteur once said, “Chance favors the prepared mind,” and so it is with being prepared for routine and specific program related audits. Our presentation focused on the types of audits (through which my colleague, Melody has capably served our institution for many years). Melody focused on the A133 audit, which is mandated by the A-133 circular to occur on a yearly basis at institutions that receive $500,000 in federal funds. It forms the basis for assessing best practices for sponsored research accounting at institutions that receive federal research dollars. The A-133 also examines how student financial aid funds are managed as well.

A-133 Audit Focus

It’s no surprise that the A-133 audit focuses on key areas of sponsored research accounting that we’re most familiar with:

  • Are the sub-contractors monitored?
  • Are direct costs and indirect costs consistently allocated across all categories?
  • Are direct cost charges beneficial and appropriate to the award?
  • Are cost transfers minimal, and if they are performed, are they timely?
  • Are internal controls present and consistently supporting purchases made on the awards?
  • Is equipment being tagged, logged and managed if purchased with federal funds?
  • Are effort reports and other technical and financial reports produced in a timely manner?
  • Are service centers managed appropriately?

It Takes a Team to Manage and Monitor Sponsored Research Funds

Melody and I then discussed the roles of central, school level and department level research administration staff in monitoring and managing sponsored research accounts – to ensure compliance and bring a sponsored project through the start up to close out process successfully.

Supporting the Investigator throughout the Award Lifecycle

I described the way in which Research Administration Services supports investigators at the Feinberg School of Medicine, a system which forms the basis of best practices for audit preparedness in a clinical research environment:

  • Ensuring accounts are direct charged whenever possible.
  • Establishing mechanisms to build in reconciliation of accounts.
  • Focus on documentation of decisions at every level to support charging.
  • Timely reporting (effort, progress reports, financial reports)
  • Communication (regular meetings with investigators, administrators and contractors)

Two Powerful Tools: Planning for Salary and Effort and Account Tracking

We reviewed two tools that our group uses to assist our investigators to manage their projects and discussed the impact that these tools have had on the departments that have used them on a regular ongoing basis.

Our salary and effort management tool (you can find this under the resources section of this site) is a living document to track and plan a faculty or staff member’s commitments. My colleague Matt Irwin and I will be talking about how to use this tool more in Milwaukee.

Our project tracker is a one year at a time view of a sponsored research project (also under the resources section of this site). Most institutions provide reports to PI’s by fiscal year – this is patently ridiculous when a project overlaps the fiscal year of an institution and has its own “year”. We’ve found that PI’s can’t keep this straight and need their own report. So we made one. This report gives a balance by month, and allows the PI to see all the information they tend to ask about in a meeting. Am I going to run out of money before the end of the year? What if I did X instead of Y? Is so and so getting paid?  It’s all there.

Here’s a Catchy Title: An Ounce of Prevention is Worth a Pound of Cure

We’ve seen it work, but it’s necessary to have a lot of patience for the investigator who needs to receive a top-line explanation about their balance because they don’t understand all the details. Or the investigator with tons of questions because they haven’t gotten a report on anything in a WHILE. The devil IS in the details.

We can’t skip this part, and we can’t skip through it, because this year, the file that gets pulled into the stack by the A-133 auditors could be ours. And as long as the government will be awarding grants and contracts, we will be held accountable for receiving them. That includes the possibility of an audit.

Three Things You Can Do Right Now

  1. Institute regular meetings with your investigators to review accounts.
  2. Review your institutional record retention policies – you’d be surprised at what you’d need to keep and for how long.
  3. Examine your institution’s systems and see where you can capture ways for documenting decisions without extra work (if you’re filling out an online or paper form for purchasing, and usually skip a section that asks for a reason for the purchase – start filling it in).

Keeping Pandora’s Box Tightly Closed: Applying and Managing Clerical and Administrative Costs to Federal Awards

images (2)Some Types of Federal Awards Can Accept Administrative Costs Under Limited Conditions  

After having it drilled into your head that administrative costs are nearly impossible to justify on federal grants, you may be surprised to learn that there are regulations that allow the charging of administrative costs to Federal awards under certain circumstances. However, it is important to review your institutional sponsored research policies regarding the proposal, documentation and administration of administrative costs on federal awards, especially in light of recent audits in this area. I attended a panel presentation today on this subject at the Financial Research Administration conference given by NCURA that was staffed by Attain consultants, and it was an excellent overview on the topic.

Circular A21, section F6B, and Exhibit C provide guidance on the circumstances under which department administrators may consider charging clerical and administrative costs as a direct charge to a sponsored project. The Cost Accounting Standards section 9905.502 supports the assignment of costs using like circumstances, and consistent allocation of costs between direct and indirect accounts.

Section F6B outlines the following requirements:

  1. The sponsored project must be a “major project” which requires an “extensive amount” of clerical support.
  2. The clerical support personnel must be specifically identified with the project activity in the documentation (budget justification and proposal).
  3. The project must specifically budget for the administrative or clerical costs (and de facto receive approval from the sponsor).

Exhibit C specifies the type of project that would be considered a “major project”, which would typically be considered a P, M or U award from the NIH, or a type of award with one or more of the following types of characteristics:

  • A large complex program
  • An award requiring extensive data analysis
  • A scientific award requiring extensive collaboration which includes making travel and meeting arrangements for large numbers of people
  • Projects where investigators are geographically unavailable to usual sources of administration (so administrators have to travel to them).
  • Database management, coordination of multiple investigator projects

Documentation is No Guarantee That Charges Are Approved – But A Budget and Justification Helps A Lot

When considering the application of administrative salary or costs to a Federal award, it is important to plan for these costs during the proposal stage, and consider the documentation of these costs in the budget and budget justification. This is the strongest type of documentation (which ties the costs and supports their justification to the scientific plan at the time of the proposal). When this is not possible, written documentation of the request and approval of the costs with the justification that are submitted to the funding agency, with the written approval should be obtained.

It’s important to name the personnel (the individual, or at minimum, the position title, if you are funding a position or portion of a position) in your budget justification. When you administer this person’s time, their activity report (if they are paid hourly) or effort report (if they are paid monthly) will tie back to the budget and budget justification. And yes – setting up activity reporting or effort reporting that documents their work on the project is a must. Note that hourly employees cannot provide an effort report due to the type of employment that they typically provide on a project.

Careful reconciliation of administrative costs on an award are necessary to ensure that the charges are hitting the correct account codes, and the proper documentation is obtained and maintained throughout the life of the award. Should the award be audited, this documentation will be needed to substantiate these charges.

The panelists noted that despite receiving approval from funding agencies, and maintaining documentation, some Universities have experienced OIG audits on administrative cost allocations and have found that they were required to remove administrative costs charged to Federal grants at the OIG request. The proposal, budget and grants management documentation will establish a reasonable, consistent allocation method between direct and indirect costs, but it does not guarantee that those costs will remain on the account in the event of an audit.

One other note of caution: an audit on administrative cost allocation methods can easily become an audit about your institution’s F&A rate. This is why it is best to be conservative when proposing, allocating and charging direct costs to grants, and why it is important to have strong institutional controls over this process.

Wondering why it’s hard to get a laptop approved on your PI’s proposal? This is why.

Managing Clinical Trials: Collaborating for Success

ClinicalTrials-Doc_PatientI am attending the Financial Research Administration conference in New Orleans from March 10-12th, and while you might think that the best thing  about being in the Big Easy is the beignets (those little french doughnuts), I’m geeking out at the NCURA meeting and I’m going to be sharing the information with you on Research Administration Nation. Think of these posts as little beignets of knowledge…sweet updates.

Right now, I’m attending a workshop on Managing Clinical Trials with David Lynch (Executive Director, Office of Sponsored Research, Chicago) and Krista Harnish (Senior Research Administrator) both from Northwestern University. Full disclosure, I’m from Northwestern, too.

The workshop reviewed all aspects of CT management, and introduced a new resource which I’m really excited about and am going to purchase for my staff from NCURA: A Primer  on Clinical Trials for the Research Administrator this was published in March 2012 and is an excellent resource.

The workshop was a presentation and facilitated discussion about the cradle to grave management of clinical trials, and included a brief presentation on the types of clinical trials, case studies, and the roles and responsibilities of individuals working on trials. The majority of the workshop focused on the work that is needed to budget and negotiate agreements that are compliant and cover all study costs, and how to conduct the study and manage expenses to meet the scientific and contract requirements (while maintaining the non-profit status of colleges and universities).

The most important budgeting and negotiation points that came out of the workshop were:

  • It’s extremely important to go beyond the sponsor template when budgeting for a clinical trial, in order to ensure that you are covering all costs. An indepth cost analysis is required for each trial, which requires working directly with the investigator and the coordinators to determine the cost components of each element, how long each required aspect of the protocol takes (so that labor costs are accurate) and working with affiliates to budget each test accurately. Participants commented that the protocol analysis often takes several sources and extensive financial analysis.
  • Understanding your institution’s experience with the sponsor can assist you in analyzing the opportunity, and developing the structure of the budget (my favorite comment was “for every request we need to make for backup information we will invoice you for $X”.)
  • Documenting the budgeting and negotiating process is extremely important for success during the post-award phase.

The key discussion in the workshop came from the post-award management material, which outlined requirements for maintaining a partnership between the investigator and the administrative management that is supporting the research team.

  • The need to facilitate and maintain communication between the PI, research team (coordinators), central office, and department business administration staff, and research administration team (whether they are cradle to grave, or a separate pre-award and research finance team), is paramount. This communication needs to start when the project is awarded and be maintained through out the life of the project, as there are changes and updates that everyone should know.
  • Using a kickoff meeting allows this team to get to know each other and establish a repoire to manage this project and future projects in order to discuss questions and concerns and maintain mission focus on completing the scientific progress.
  • The team analyzes the contract and anticipates issues together – appropriately bringing roles to bear on issues that they are responsible for, and focuses on milestone acheivements together.
  • Follow up meetings are scheduled and maintained by the research administrator.
  • The meetings are maintained to report to the PI about his/her financial expenditures, receive updates on scientific progress and to manage the account and report to the sponsor.

In the post-award arena, a significant challenge that many institutions face is managing balances on clinical trial accounts. The workshop participants discussed scenarios when PI accounts have funds remaining, and institutional policies for managing those funds.

Three things to remember when managing positive balances in clinical trial accounts at the end of an award:

  1. Conduct a reconciliation of charges. Ensure that all appropriate and expected charges, including PI effort, participant remuneration, and other expenses, have hit the account.
  2. Read the contract. Do not assume that a balance can be transferred into an individual PI account. The balance should be transferred into a University account with a similiarly defined research purpose.
  3. Balances on PI accounts jeopardize the institution’s non-profit status when not properly managed and closed out into proper accounts; develop a policy at your institution and education your PIs that these funds belong to the University, not to them.

The bottom line: It’s all about collaboration for success – research administrators need to work with clinical research coordinators  and finance staff to administer clinical trials and serve investigators. When we do – clinical trial participants benefit, and that’s what its all about.

Justification Nation Part 9: The Hard Truth – A Budget Justification Is Never Fully “Approved”

A21Expenses are Not 100% Allowable Until they Are Approved by the Grants Management Specialist

The budget justification is required in order to demonstrate that the research plan and budget are closely aligned and that the proposed expenses are reasonable.

However, the investigator can propose a research plan, budget for it, and receive funding. The program officer can even approve the investigator’s activities and ideas, and encourage him or her to proceed. But the investigator can still be told that it is not possible to charge the project for expenses that were proposed (and previously “approved”) when the charges are reviewed by the grants management specialist for the award.

Why does this happen?

  1. At the proposal stage (when the institution submits the application) the institution reviews the application guidance against the science and submits what it believes to be the most compliant proposal to the agency but the agency needs to confirm that the proposal meets the guidelines.
  2. The proposal is received by the agency (if it is a federal agency) and typically reviewed by a scientific panel to be approved on the basis of its scientific merit, and whether or not the budget is appropriate to achieve the scientific aims. (Is it realistic or not – not whether the items proposed are compliant with A21.)
  3. The investigator receives approval for the application and will receive a preliminary budget review, and may be asked to re-budget (if there is a funding reduction) and at that time, some items may be found to be unallowable.
  4. The investigator will start work, and then the grants management specialist or other financial manager will work with the research administrator to evaluate certain transactions while the research project takes place. This individual, along with the university grants and contracts financial specialist, has a key role to play in the accurate financial management of your account and whether or not a charge is allowable on the award.
  5. An auditor of an award also evaluates allowable charges and has the ability to determine whether a charge can stay on the account or whether it has to be removed.

What Can A Research Administrator Do To Help Support the Justification of Allowable Costs?

  • Write complete budget justifications, don’t cut corners. (Don’t provide too much information – know the type of information required for each type of cost and be complete – in order to ensure that you can document the basis of each cost when it is needed.)
  • Maintain documentation for proposals (budgets and budget justifications) as well as proper version controls in an easy to find electronic filing system. Follow the “hit by the bus” method (if you were hit by a bus – could someone step in to your role and find everything you were working on? Would they understand the naming conventions for your files?
  • Maintain the justifications for changes, decisions, re-budgets, allocation methods, using a system that is easy to detect.
  • If you’ve dealt with any sort of issue, document how you handled it, and provide documentation for your central office.
  • Work with your central offices (sponsored research and accounting offices) to problem solve grants management questions when they arise before working with the funding agency. Develop and maintain all documentation related to the interactions related to questions related to allowable costs.

Documentation that links the science to a proposed cost – and then the decision that supports the cost and whether it is an allowable charge on the sponsored project is the end result of our activity. If there is any break in this chain – something that makes us question the allowable cost, our need to document the discussion and decision to charge the sponsored project is paramount.

Helping our investigators understand that this process is never truly complete – because their work is evolutionary by nature – is important. As research administrators, we can assist our investigators by maintaining our follow up, asking questions about the status of their projects.