Once an award is accepted the Grants and Contracts Administrator (GCA) will help setup the award and assist the Principal Investigator (PI) and the research staff to navigate areas of reporting and compliance when managing an award. Specific GCA support includes the following:
Spending funds according to allowability, allocability &, reasonableness
Spending based on budget projections
Managing personnel effort
Submitting progress reports
Meeting project deliverables
Assisting with any necessary award modifications
Below are aspects of award management that need consideration throughout the life of a research project.
An important aspect of award management is ensuring that expenses are charging correctly. PIs should work with the GCA to stay aware of when spending may begin on a project, how costs are being charged and if costs are allowable.
Allowable vs. Unallowable Costs
Both the sponsor and Duke University have policies regarding the allowability of an expense on a sponsored research project. The NIH policy on cost principles can be found in the NIH Grants Policy Statement; for other sponsors, refer to their websites for specific guidelines. Duke University GAPS provide guidance on internal practices for charging costs to sponsored projects. Allowable costs typically are:
- Allocable to the project
- Conform to the limitations or exclusions set by the sponsor
Unallowable expenses are not eligible for reimbursement by the sponsor and cannot be cost shared. These typically include:
- Alcoholic beverages
- Alumni events
Facilities & Administrative Costs (F&A)
Often called indirect costs, F&A costs are expenses incurred for a common or joint objective and cannot be associated with a specific sponsored project. These costs include utilities, repair and maintenance, university libraries, building and equipment depreciation. All sponsored research projects include F&A charges in the project budget at a rate set by Duke as negotiated with the sponsor. Contact the GCA for guidance in determining if an expense is project specific or should be included in F&A costs.
When to Start Charging Expenses
If the award is received, Duke issues a fund code, and allowable costs associated with the project may be charged. If during the course of the project an expense is charged in error or to the wrong project, let the GCA know immediately. If the GCA is notified promptly, the change can be moved to the correct project. If not notified in a timely manner, then the expense will be written off to a discretionary or start-up account. If the charge does not belong to the project, the GCA will research the expense and have it removed.
Purchasing Laboratory Supplies
The standard process for ordering supplies is completed through the Buy@Duke web portal. Guidance on using Buy@Duke can be found here. Typically, research technicians and laboratory personnel will initiate a cart in Buy@Duke. For help submitting an order, the GCA or Divisional Administrator can assist. High dollar purchases, such as major equipment, will require multiple approvals so submitting ordering early is recommended.
Research grants must incur expenditures within the project period as outlined in the award document. Expenditures in excess of the award budget that result in overdrafts and/or deficits from expenditures over the revenue received must be resolved. In order to avoid an overdraft or misuse of funds, and to make sure that the research is proceeding in accordance with the established scope of work, the GCA will provide routine reports to the PI that summarize expenditures on the fund code. These expenses will include personnel and effort devoted the research, as well as any supplies, equipment, travel, or other expenses that are incurred. There is also a suite of reports in Duke at Work (called MyResearch, accessed with Duke NetID and password) that the PI may run independently that will help keep track of effort and expenditures over the life of the grant.
A subaward is an agreement between Duke University and another entity to carry out the scope of work on a grant. Depending on the project, Duke may issue a subaward to another institution or Duke may receive a subaward from an outside entity.
When a subaward is issued to an outside institution, Duke University assumes responsibility for monitoring the Subrecipient (or “Sub”). Working in conjunction with the Sub, the PI is responsible for monitoring project activities throughout the life of the award to ensure project aims and goals are accomplished and sponsor terms and conditions are met. To support these efforts, the PI should:
- Confirm the statement of work. Make sure the subaward is in line with the scope of work.
- Review any non-standard terms and conditions of the subaward during the subaward agreement negotiation process
- Maintain regular contact with the Sub PI regarding all technical aspects of the project.
- Participate in project conference calls
- Review and approve deliverables, as defined in the subaward agreement, including data and progress reports.
- Review and approve Sub invoices in a timely manner.
- Notify the GCA of any necessary subaward amendments, modifications or extensions.
The GCA will help PIs monitor, track and review subaward invoices for allowable and allocable costs consistent with the subaward budget. Invoices should be submitted to Duke University in accordance with the subaward agreement, but generally not more frequently than monthly. The PI should contact the GCA if there are invoice issues. Invoices should be rejected until all issues or concerns have been resolved. The PI should discuss with the GCA any Sub issues.
If Duke receives flow-down funds to carry out work on a grant from an outside institution, then Duke is the Subrecipient. Subawards are established for the period of time authorized by the prime organization per the terms of their award notice. This is typically in one year increments. All terms and conditions from the sponsor apply to Duke as the Subrecipient. At the end of each project period, an amendment or new agreement is required to extend the performance period, modify the Duke’s scope of work as a sub, and/or add funds to the subawardee. Prior sponsor approval is required to change the Subrecipient’s scope of work if it alters the sponsor approved aims.
Effort management is important to consider at all stages of the research process, however there are several key aspects to consider at time of award through the conclusion of the research. These include:
- Effort changes (navigation of planned and unplanned changes)
- Key personnel
- VA appointments
- Effort on Career Development Awards (K Awards)
- Effort certification (ES-DUHS effort and/or University effort)
Faculty and staff time is often divided among a variety of tasks, such as teaching, research, administrative responsibilities, clinical services, etc. Effort for Duke faculty is typically considered in one of two main ways: University effort or Total Professional Effort (TPE). University effort is the amount of time spent only on Duke University activities (ex: research, instruction, administrative roles). TPE accounts for an individual’s total combined effort at Duke University, the Durham VA Medical Center and Private Diagnostic Clinics (PDC). The total distribution of effort dedicated to all institutional activities for an individual must be 100%, including cost sharing commitments.
Committed effort is the portion of University effort that will be devoted to sponsored research activity, whether the sponsor pays their salary or not. When submitting a proposal through Duke University, use Institutional Base Salary (IBS; the portion of the total salary being paid by the University, not by the VAMC or PDCs) to determine the direct cost associated with the proposed effort. Effort proposed for a PI or other key personnel in a grant application, typically in the budget and/or budget narrative, becomes a commitment (or obligation) the university must fulfill unless explicitly modified during award negotiations with the sponsor. The cost associated with committed effort may be borne by the sponsor (charged to the grant or contract) or by the institution (documented as cost-sharing).
Many activities cannot be charged to a sponsored project. Examples include:
- Writing a proposal (research administrative effort)
- Serving on an IRB, IACUC or other research committee
- Serving on a departmental or University service committee
Duke University is at risk if non-project related administrative effort and expense is reimbursed by sponsored projects. While sponsors accept up to 12 calendar months (100%) for active effort distribution, Duke University’s SOM maximum effort policy specifies that a faculty member (both tenure-track and non-tenure track) should set aside committed effort for university related administrative activities. In addition to proposal preparation and submission, administrative activities include monitoring email, departmental meetings, normal personnel matters, mentoring, instruction, uncommitted cost sharing, projects where PI has zero committed effort, and other institutional activities not related to sponsored projects.
A minimum of 5% administrative effort is necessary for faculty writing proposals, leaving 95% (or 11.4 calendar months) available for sponsored research activities. For faculty with administrative roles, a minimum of 10% administrative effort is necessary, with no more than 90% (or 10.8 calendar months) for sponsored research.
Exceptions to the SOM maximum effort policy must be documented and requested through the Vice Dean of Research/Basic Science of the School of Medicine or the Vice Provost for Research.
If faculty experience a shift in their TPE (ex: reduction in VA 8ths) then the amount of time available to commit to research projects may also change. This may prompt a significant change in effort that could require sponsor approval. Discuss any pending changes to TPE with the GCA.
Proposed effort on a project is an estimation of the time needed to complete the responsibilities associated with the project. As such, it is understood that effort commitments may fluctuate based on the scientific needs or results of the project. If a proposal is awarded at a lower amount than requested and effort adjustments are needed, these should be addressed at the time of award. The GCA can help ensure the necessary effort adjustments are made and approved by the sponsor.
Once an award has been accepted by Duke University, significant effort reductions for key personnel need prior written approval by the sponsor. Significant effort reductions include:
- Reduction in sponsor approved effort by 25% or more by key personnel, regardless if effort is paid by sponsor or cost shared.
- Absence for any continuous period of 3 months or more.
- Effort changes as defined by sponsor policy or guidelines.
- Reduction or removal of effort during a No-Cost Extension (NCE) may require prior approvals. Work with the GCA to determine what, if any, approvals are needed.
If the receipt of an award increases an investigators total effort commitments to greater than 100% (for all institutional activities), the investigator must adjust the level of committed effort on the new or existing projects or refuse the award. The GCA can help determine the PI’s current and pending effort commitments and secure the necessary approvals for effort adjustments.
Key personnel are determined during proposal development. They are individuals who contribute to the scientific development or execution of the project in a substantive, measurable way, whether or not salaries are requested, and are not typically easily replaced. Sponsor Key Personnel are determined by the sponsor, always include the project PI/PD, and in the case of NIH awards, are identified by name on the Notice of Award (NoA). If a change in key personnel becomes necessary, work with the GCA to navigate the process.
To assure to the federal government that there is no possibility of overlap in effort and/or dual compensation for the same work, investigators with a joint appointment between Duke University and the VA are required to have a Memorandum of Understanding (MOU) describing the responsibilities at both the university and the VAMC. MOUs are active for one year and must be updated annually or when faculty effort distribution between Duke or the VA changes.
Since the VA defines their work week as 40 hours, a faculty member with a joint appointment can exceed 100% by the VA definition. A full time VA appointee can submit grant applications through Duke University (if Duke is the awardee), provided that the investigator:
- Has the necessary time at Duke to complete the work, and
- There is no possibility that any funded research (particularly Federal) is also funded through the VA appointment
By signing the VA MOU, the faculty member is certifying that:
- There is no possibility of dual compensation for the same work
- There is no actual or apparent conflict of interest
- The PI serves under a joint appointment between Duke and the VA
Career Development Awards, or K Awards, are available through NIH to new and established investigators to foster the development or advancement of a career in research. New investigators can take advantage of mentored awards with the goal of protecting time to gain experience that will strengthen independent research endeavors. Non-mentored awards are available to established investigators seeking protected time to expand their potential to make significant contributions to a field of research.
Because the awards are designed with protected time in mind, PIs interested in career awards should be aware of terms and conditions regarding effort and eligibility. Both mentored and non-mentored career award recipients are required to devote and maintain a minimum level of effort and must have a full-time appointment at Duke University. Regardless of the type of career award, effort minimums should be maintained unless the prior sponsor approval has been secured. This includes any No Cost Extension performance periods.
Mentored K Awards
Mentored K award recipients are typically required to devote a minimum of 9 calendar months (75% effort) of their University effort to the project, however it is recommended to check the sponsor agency’s guidelines for the exact effort floor. The remaining 3 calendar months (25% effort) can be divided among other projects and activities that are consistent with the goals of the career award. During the final years of a mentored K award, investigators are encouraged to apply for additional research grants where they devote complementary effort without salary support.
Non-Mentored K Awards
Non-Mentored K award recipients generally allocate a minimum of 3-6 person months (25-50% effort) on research and career development activities during the award period and may receive additional salary support from other NIH awards. Refer to the sponsor agency’s guidelines for the exact effort requirements.
During the final two years of a mentored career award, recipients may reduce effort if the sponsor terms allow and the recipients have successfully competed for peer-reviewed research awards from a Federal agency. If a Federal award is granted and the investigator is PD/PI, effort may be reduced to no less than 6 calendar months (50% effort) and be replaced by effort and corresponding salary from the research award so that total effort remains at 9 calendar months (75% effort) for the duration of the career award.
Effort certification is Duke’s process for providing assurance to sponsors that faculty and staff have met their commitments for sponsored research projects. Federal guidelines require that institutions receiving federal awards have a process to document and certify how effort and salary are spent supporting federally funded projects. Duke University meets this requirement using Effort Certification Cards available via the online system called Effort Certification Reporting Technology (ECRT). Faculty and staff charging effort to sponsored projects or receive supplemental pay are required to certify their effort annually (as identified in GAP 200.170, Effort Reporting) to comply with University and external regulations. Non-compliance with this policy can result in disciplinary action, including the prohibition of future proposal submission.
Why is effort reporting important?
Federal awards represent a significant portion of Duke’s externally sponsored research activity. Salary expense is the largest direct cost component included in budgets. Paying salaries with federal funds requires an institution to have a system that provides auditable records on how individuals participating in sponsored agreements actually spend their time. In recent years, the federal government has become very active in reviewing the effort reporting requirement. Federal audit disallowances can result in large financial penalties for institutions. Additionally, criminal charges may be brought against an individual certifying falsified effort.
Who should certify effort forms?
Effort should be certified by the PI. Faculty and staff who have effort on sponsored research projects and/or receive supplemental pay will be required to certify annually. Those who have Effort that Supports Duke University Healthy Systems (ES-DUHS) effort will need to confirm effort on a quarterly basis. A supervisor or employee who has first-hand knowledge of the time spent by the individual may certify as a proxy if the PI is not available to do so. Certification must reasonably reflect all the effort for all the activities that are covered by an individual’s institutional based salary (Duke University effort only), and as such the certifier must understand what they are signing and have supporting documentation.
Two Types of Certification
Effort certification takes place through ECRT which is a part of the Duke at Work website. Depending on the type of effort you had during the fiscal year, the PI may be required to certify both quarterly for ES-DUHS effort AND annually for sponsored research effort. Faculty and staff who qualify will receive an email notification from the ECRT system with instructions specific to the certification required by the individual.
Annual Certification – Sponsored Research Projects
All faculty and staff working on sponsored research projects must certify their effort annually. Institutional Base Salary (IBS) and Supplemental Pay must be certified separately. By certifying, the individual agrees that the effort distribution in ECRT accurately reflects how their time was spent on specific projects or activities, not how he or she was paid (although these two elements are usually related).
- Institutional Base Salary (IBS) - is based only on University Effort and does not include PDC, VA or other outside effort. IBS is used for the Faculty Effort Certification and in the calculation of grant budgets.
- Supplemental Pay/Extraordinary Pay - Supplemental and extraordinary pay is for assignments that fall outside the faculty member’s primary responsibilities. Examples include: honoraria, teaching, course development, manuscript reviews, etc. that are paid through the University. This does not include pay for outside consulting.
Quarterly Certification – ES-DUHS
Faculty and staff that have Effort that Supports Duke University Healthy Systems (ES-DUHS) effort funded from University sources (effort charged to G/L Account 600200) are asked to attest to their effort on a quarterly basis (September, December, March and June). The funding for this effort is reimbursable through the hospitals’ cost reports, and it is essential that the effort is appropriately identified and certified. Those who are identified as having ES-DUHS effort will receive an email notification and should confirm effort at that time. This serves as an attestation that the effort reported is true and accurate.
What if an effort card is not correct?
If the Effort Card is not consistent with actual effort, contact the Primary Effort Coordinator to determine the discrepancy and process corrections, if needed. The name of the assigned Effort Coordinator can be found at the top of the Effort Card.
Progress Reports and Deliverables
Sponsors generally require updates on project goals and the status of research achievements throughout a project. Once the grant is awarded, the PI and the GCA will review the award notification for all requests for deliverables and progress reports.
NIH requires Research Performance Progress Reports, or RPPRs (sometimes called non-competing renewals) before the end of a current budget period, usually due 45 days prior to the start of the next budget period. The GCA will work with the PI to complete the RPPR, both internally in Duke’s systems, and through eRA Commons. The GCA will complete all administrative sections, while the PI will be responsible for the scientific progress sections and for attributing all relevant publications to the grant. The GCA can provide an outline of required questions and instructions on how to complete each section.
In order to submit the RPPR in eRA Commons, Duke requires that an internal SPS record route to ORA 7 business days prior to RPPR report deadline. The GCA will complete the record with input from the PI.
Once the PI has confirmed the RPPR is finalized, he or she will route the RPPR in Commons to the designated ORA official, who will in turn submit the progress report on the Duke’s behalf.
For non-NIH awards, the GCA and PI will review the award terms and determine a timeline and list of responsibilities to complete the progress report and any other existing deliverables (e.g. technical progress reports, invention reports, any contractual products).
During the course of a research project, it may be necessary to make changes to the research that differs from the original communication to the sponsor. These changes could be necessitated by a shift in the research goals, or in the process necessary to achieve the original aims. The PI may need to reallocate funds, change the scope of work, adjust the timeline for project completion, or even shift the project responsibility to another investigator. The sponsor will generally require advanced notice and approval of any change which would impact the research goals.
Administrative Modifications are changes to an existing award that do not affect the approved budget total or the approved performance period of the award but changes terms or conditions of the award. These changes normally lift a restriction set in the award terms and may be initiated by the PI, the department or the sponsor.
Types of Modifications
No Cost Extension
A No Cost Extension (NCE) is a request for additional time, extending the last year or budget period of an existing award without requesting additional funds. Approximately 90 days prior to an award’s end date, the PI should talk with the GCA to determine if an NCE is needed. NCE requirements vary depending on the sponsor.
Under Expanded Authorities from NIH, Duke may approve a one-time NCE for specific types of grants that meet Duke-approved circumstances (such as needing additional time to adequately complete a study). Requests for No Cost Extensions must be received by the Office or Research Administration (ORA) at least 15 days prior to expiration of the current project period. Grants may be extended in one-month increments for up to 12 months. Please note that the existence of remaining funds at the end of the project period is not a sufficient or acceptable justification for a NCE. The GCA will complete the NIH No Cost Extension Request Form and submit to ORA for review, approval, and updating in eRA Commons.
Requests for no-cost extensions beyond the first year extension require a letter signed by the PI and an ORA signing official. ORA will submit the letter to NIH for approval. The request for extension should be submitted to NIH at least 30 days prior to the current NCE project period expiration date.
Changes in Key Personnel Effort or PD/PI Status
Key personnel are those considered to be of primary importance to the successful conduct of a research project. For the NIH, key personnel are named in the Notice of Award (NoA). Prior approval is required if the key personnel:
- Withdraw from the project
- Will be absent for any continuous period of 3 months or more
- Reduce the level of effort devoted to project by 25% or more from what was approved in the initial competing year award
The sponsor approved effort commitment for key personnel may be reduced to a measureable level of effort during the NCE period unless terms and conditions prohibit reductions. Prior approval requests must be approved and signed by the project PI, the owning department, and ORA and must include a justification for the effort change and address any changes that may impact the existing scope of work. For other sponsors, the GCA will review award stipulations and determine if prior approval is necessary.
If the PI steps down from their role on the project, notify the sponsor prior to the effective date of the change. To assign a new PI to the role, a prior approval request must be submitted to ORA for review and submission to the sponsor.
If the PI is transferring to a different institution, please see Early Termination/PI Transfer of Award.
Carryforward consists of unobligated funds remaining at the end of any budget period that, with the approval of the sponsor, may be carried forward to another budget period to cover allowable costs of that budget period (whether as an offset or additional authorization). NIH allows carry-forward approval by either the Grants Management Specialist (GMS) or through Duke’s expanded authority. Certain sponsor awards may not allow automatic carryforward of unexpended funds for each budget period. The PI and GCA should review the sponsored award terms closely to determine if advanced sponsor approval is needed for carryforward of unexpended funds to the next budget period.
Scope of Work Changes
Any changes to the proposed scope of work require sponsor approval. The PI should prepare a letter describing the scope change needed, the rationale for the change, and the impact the change may have on the budget. This letter will be signed by the PI and ORA and submitted to the sponsor by ORA.
A change in scope may also affect IRB and/or IACUC protocols. In that event, a modification to the existing protocol must be processed and approved by the appropriate review board. All amendments to an existing protocol should be processed using Duke’s eIRB website.
Rebudgeting is the reappropriation of a portion of the approved budget from one budget category to another and does not involve the increase or decrease of the approved budget total.
For the NIH, a change of 25% or more in any budget category or a change from equipment to another category of the approved budget may require prior approval if the incurrence of costs is associated with or is considered to be a change in the scope. (For example: the shifting of substantive programmatic work to a third party through a consortium agreement will result in the shifting of personnel, supplies and a portion of indirect costs to consortium/contractual costs.) For other sponsors, the GCA will check grant guidelines to determine when prior approval is required for re-budgeting.
Once rebudgeting is approved by the sponsor and Duke, the GCA will process the rebudget in Duke’s accounting system and it will be routed via Duke at Work to the PI for final approval. The PI can access the rebudget in his/her Universal Worklist on the Duke at Work website. Step by step instructions for approval can be found here.
Early Termination/Award Relinquishment
Early termination is the process required to end an award before the published expiration date. A common reason for terminating an award early would be the departure or transfer of the PI to another institution or organization. With the departure of the PI, the award is either closed out or transferred with the PI.
Early termination of an award requires approval from both the administering department at Duke and from the sponsoring agency. NIH awards require that prior approval be requested and approved at least 90 days before the anticipated termination date of the award. A request for a change of recipient organization must include an Official Statement Relinquishing Interests and Rights in a Public Health Service Research Grant (PHS 3734, aka relinquishing statement). For other sponsors, refer to the terms and conditions of the award.
To ensure that an award is successfully terminated, transferred or relinquished:
- The PI and department will notify the GCA of intent to transfer or terminate an award at least 90 days prior to the transfer/termination date. Notify the GCA if there are subcontracts related to the award to allow sufficient time to terminate the subcontracts.
- The GCA will obtain proper institutional approvals and submit the prior approval request to the sponsor 90 days prior to the transfer/termination date.
- Duke’s Office of Sponsored Programs (OSP) will provide the PI and GCA with an estimated balance at time of termination (broken out by direct and indirect costs).
- For NIH awards, the GCA will complete PHS 3734 Relinquishing Statement and verify termination date before submitting to the Office of Research Administration (ORA) for review. ORA will sign and submit the relinquishing statement via eRA Commons. For other sponsors, the GCA will review sponsor guidelines for steps to begin transfer or termination.
Upon receipt of the sponsor’s approval documentation, the closeout process must be completed per the terms of the award or per the sponsor’s instructions. If there are subcontracts related to the award, the GCA will confirm the approved termination date upon receipt of the sponsor's approval and will notify subrecipients of the official termination date.