Post-Award Management
The process of managing sponsored projects is a shared responsibility between the PI, the department/administrative staff, the Office of Sponsored Programs (OSP), and the Office of Grants Management (OGM). Each has unique areas of primary responsibility.
The PI has primary responsibility for accomplishing the technical goals of the project, while also complying with the financial and administrative policies and regulations associated with the award. Although PIs may have administrative staff to assist them with the management of project funds, the ultimate responsibility for the management of the sponsored project work and funds rests with the PI.
The Office of Sponsored Programs (OSP) will advise and assist PIs in complying with the requirements of their project sponsor. See Post Award Administrative OSP webpages for more information.
The Office of Grants Management (OGM) has primary responsibility for the financial reporting, invoicing, effort reporting, cash management requirements, and audit coordination of sponsored projects. See Post Award Financial OGM webpages for more information.
Post award responsibilities of the PI include:
- Executing the technical aspects of the program, including the reporting of project progress to the sponsor as outlined in the terms of the award
- Staffing the project, initiating employment and payroll actions, and supervising project personnel
- Maintaining fiscal stewardship over the sponsored project, ensuring the reasonable and prudent use of the sponsor's funds
- Spending no more than the amount authorized by the sponsor for the budget period
- Carrying out the project’s financial plan as presented in the funded proposal, or make changes to the plan following a prescribed set of policies and procedures
- Meeting periodically with OGM to review expenditures and to assure their appropriateness and correctness.
- If administrative revisions are necessary, the PI will provide OSP a rationale and information to support the request (e.g. budget revisions, no cost extensions, changes in objectives/scope, absence or changes in key personnel). OSP will determine if sponsor approvals and/or notifications are necessary. If sponsor approval is required, OSP will submit the required request and documention to the sponsor.
- Complying with all University policies and procedures related to project management and personnel practices
- Complying with all applicable sponsor rules, regulations and/or terms and conditions of the award
Post Award Management - Administrative OSP
Post Award Administration
Frequently, projects change or evolve from how they were initially proposed to or awarded by the sponsor. Some changes occurring over the life of the project require prior written approval from the sponsor and/or OSP. The level at which approval may be granted depends upon the type of award and the sponsors terms and conditions governing the award.
Some award changes may require Sponsors prior approval before processing them internally. Federal administrative requirements allow agencies to waive certain cost-related and administrative prior approvals; these are known as expanded authorities. Prior approval may not be necessary on some changes in the case of federal sponsors who grant expanded authorities.
Examples of changes that may require prior sponsor approval include: no-cost extension, budget extension, PI change, carry forward, changes in the scope of work, early termination, relinquishment etc.
It's important that PIs read and understand the terms of their award, sponsor guidance and additional instructions below based on the type of award change being requested.
Post award changes are processed through myResearch Grants by accessing your Award (AWD#) and select Request Award Modification function. For assistance, contact your departmental administrator or your OSP Specialist. Post award administrative functions are managed by OSP.
When committed support is a reasonable expectation (e.g. NIH non competing segments),
OSP will extend an award for up to 3 months without backstopping pending receipt of
Notice of Award from sponsor. Any other continuation award extension requests that are pending sponsor action will
be reviewed by OSP on a case-by case basis, and may be subject to to the Advance policy. Carryover is when the balance of unused funds at the end of a Budget Period is transferred
(or carried forward) into the following Budget Period. Some sponsors allow automatic
carry forward of funds from year to year, others require prior approval. Carryover requests that require prior approval must be coordinated through OSP. OSP will coordinate with OGM the submission of carryover requests since no expenditures
from the current Budget Year can be encumbered, and final invoice for the current
Budget Year must be submitted in advance or at the time of carryover request. Changes that significantly alter the scope of work as proposed may need to be approved
by the sponsor. A no-cost extension (NCE) is defined as an extension of time to a project period and/or
budget period to complete the work of the grant or contract under that period, without
additional federal funds or competition. This one-time extension may not be exercised
merely for the purpose of using the unliquidated balances. Recipients are not authorized
to extend an award that contains a zero balance. Additionally, a project’s originally
approved scope cannot change. Note that sponsors may have limitations on the timing
and notification of NCE requests. For guidance and assistance, contact your OSP Specialist. No cost extension requests, like all award modification requests (otherwise referred
to as AMR’s), require internal approval before the request can be submitted to the
Sponsor. This process applies to both grants and contracts regardless of the funding
source. Below are the instructions for preparing the internal request in myResearch: Request the no cost extension in myResearch (myR) by clicking on the “Request Award modification” button on the myR AWD landing
page: Once your specialist receives the AMR, it will be reviewed and if it is in order,
it will then be submitted to the sponsor or the PI will be notified they are cleared
to submit to the sponsor in those instances where they are the only point of contact
on record with the sponsor. NCE documentation by selected sponsors: National Institutes of Health (NIH) NIH Grantee approved first NCE’s are completed by the OSP Authorized Organization Representative (AOR) in eRA
commons. You must first complete a MyR AMR; state the # of calendar months you wish to request an extension for (maximum 12),
whether there are any personnel effort changes or removals in the NCE period and,
ideally, a brief justification for how the funds will be used in the NCE period. With the exception of grant programs that have an effort requirement, or where terms
and conditions prohibit such reductions, NIH will not require prior approval for the reduction in effort for Senior/Key personnel named in the NOA for a NCE.
The recipient is reminded that active awards must have a measurable level of effort. See Section 8.1.1.3 of the NIH Grants Policy for more details. Once approved, your OSP AOR will submit the first NCE in eRA Commons. The NCE will
be granted immediately and then the OSP specialist will update the internal award
record to reflect the new end date for the project. Sponsor approved second NCE is also completed by the AOR in eRA Commons however the request requires the following
documentation to be uploaded (these should also be uploaded to the internal MyR AMR
request): Please note that for the second NIH NCE, OSP will need the above items in three separate
uploads in the MyR AMR: The AMR will remain in review until a determination is made by the sponsor. If approved,
a Notice of Award will be issued. The OSP will then update the internal record accordingly.
If it is not approved, the AMR will be declined and the award will term on the last
day of the first NCE period. National Science Foundation (NSF) Grantee approved (first) and second NCE's are initiated via research.gov by the PI. You must first complete a MyR AMR for internal approval prior to initiating and routing the
Research.gov request. Once you submit the NCE via the sponsor portal, this will route
to your OSP AOR for final review & submission. Instructions for requesting a grantee approved & second no-cost extension in Research.gov: Click the “Save & Submit to NSF” button at the bottom of the page. This will route
the request to the OSP office. The grantee approved NCE will be granted immediately and then the OSP specialist will
update the internal award record to reflect the new end date for the project. The second NCE request requires sponsor approval. OSP must await an amendment from
the NSF approving the request before the award can be updated internally. If the request
is not approved, the AMR will be declined and the award will term as of the last day
of the first NCE period. For guidance on what is required for NCE requests for other sponsors (Federal or Foundation),
please submit an inquiry to osp_postawards@stonybrook.edu The following guidance is provided to assist principal investigators (PIs) and departments
in taking the proper steps when a PI’s relationship to Stony Brook University (SBU)
changes. PIs are responsible for timely closure of studies or transfer of PI responsibilities
in the event of their move to/from another institution. Some sponsors require prior approval for budget revisions while many sponsors allow reasonable budget revisions without prior approval. Review carefully
the terms of the award and sponsor guidance to ensure compliance with rebudgeting
requirements. In all cases when prior sponsor approval is required, please submit your request through
myResearch Grants by following these instructions. Note: NIH accepts email concurrences and NSF notifications can be done in Fastlane. Contact your OSP Specialist with any questions regarding these requests. Generally, a significant reduction in effort (25% or more) for the PI or other key
personnel requires prior sponsor approval. Reduction includes absence from the project
for an extended period of time of 3 months or more. Review your notice of award and other sponsor guidelines before sending requests to
OSP for review and submission to the sponsor. Submit a request to OSP via myResearch Grants following these instructions. Explanation of necessary change and any budgetary or scope of work change must
be provided. By accepting external funding, our institution agrees to comply with the terms and
conditions associated with the awards. It is a shared responsibility of the PIs, departmental
business/administrative offices and central offices. Generally, grants, contracts,
cooperative agreements and other funding mechanisms may require some or all of the
following reporting: technical, financial, patent and invention, and property inventory
for both purchased and sponsor supplied equipment. While the Offices of Grants Management
and Intellectual Property Partners are responsible for the financial reports (e.g.
FFR, SF 425, quarterly financial disclosure, cumulative invoices), property inventory
and patent and inventions reports, PIs are required to understand and comply with
the technical/programmatic reporting requirements of their awards, which involves
becoming familiar with reporting formats, templates and any online submission portals. These reports may be referred to by the sponsor as: RPPR (Research Performance Progress
Report), Technical Report, Performance Report, Project Report. In some cases (e.g. NIH RPPRs), the PI and the Office of Sponsored Programs (“OSP”)
work together to complete and submit the report. In others, PIs are encouraged to
discuss and share the report with OSP prior to submission (e.g. NSF). Outlined in his section are the types of reports that may be required and the individual
or department that is responsible for the submission of these reports. Financial Reporting Not all budgets require financial reporting. In particular, for budgets that are invoiced,
the invoice transaction detail may serve the same function as a financial report for
the sponsor, allowing them to monitor the allowability of expenditures. If a sponsor contacts you about financial reporting, please forward their email to ogm@stonybrook.edu. If you have questions or concerns about a specific budget’s financial reporting, please
contact your OGM Sponsored Award Analyst. Invention Reporting Agencies generally require institutional signature or submission in sponsor systems
for both positive and negative invention statements. Contact Maureen Case in IPP at maureen.case@stonybrook.edu. Property Reporting If you have questions about whether an annual Government property inventory and report
are needed for your award, contact your OGM Grants Analyst. General property questions may also be sent to ogm@stonybrook.edu. Award Closeout OSP and OGM have developed a checklist in an effort to assist Principal Investigators
transition activities prior to termination of their funded awards. Sponsors generally require a basic set of reports in order to close an award. It is
important to complete all the requirements and it is important to do so in the time
frame stipulated by the sponsor. The closeout documentation and the time frame for
submission are stated in the terms and conditions of the award or contract. The usual
terms require that the following reports be submitted within 30, 60 or 90 days of
expiration of the award: Non-compliance in this regard can lead to debarment of the PI from receiving subsequent
grants from the sponsor. Ultimately, it can even lead to the debarment of the University
from receiving grants from the sponsor because the University is held responsible
for all required closeout documents. The Principal Investigator/Project Director (PI) OGM IPP PIs are required to understand and comply with the technical/programmatic reporting
requirements of their awards, which involves becoming familiar with reporting formats,
templates and any online submission portals. These reports may be referred to by the sponsor as: RPPR (Research Performance Progress
Report), Technical Report, Performance Report, Project Report. In some cases (e.g. NIH RPPRs), the PI and the Office of Sponsored Programs (“OSP”)
work together to complete and submit the report. In others, PIs are encouraged to
discuss and share the report with OSP prior to submission (e.g. NSF). OSP supports PIs with their technical reporting obligations by sending them automated
email reminders from ovpr_myresearchgrants@stonybrook.edu 60, 30 days before technical reports are due, as well as on the due date. This applies
to awards set up in myResearch after February 2020. The email subject line contains
the words IMPORTANT ACTION REQUIRED REGARDING TECHNICAL REPORTING. PIs are encouraged to open these emails and follow the instructions. Here’s an example
notification: IMPORTANT ACTION REQUIRED REGARDING TECHNICAL REPORTING - PLEASE READ AND RESPOND
ACCORDINGLY Note that for awards set up prior to February 2020, the email notification to PIs
will be from Razeema Sahib, Account Establishment & Maintenance Unit. A copy of the
report needs to be provided to OSP via email, according to the email instructions. If a PI cannot submit a technical report by a required due date, s/he should contact
the sponsor, before the due date, and copy OSP, requesting an extension. If the PI
provides suitable justification, OSP can also contact the sponsor to request an extension
on the PIs behalf. If a PI has not submitted a technical/performance report and provided OSP proof of
submission prior to the due date, OSP will take the following corrective actions: Delinquent reporting is a significant issue and can negatively impact payment on individual
awards and future funding for the entire university, and it can damage SBU’s reputation.
Furthermore, audits, including our annual A-133 audit, encompass reporting compliance,
so federal penalties and other consequences due to noncompliance are real possibilities.
Among the actions sponsors can take when reports are not received by the deadline
are the following: - The loss of expanded authorities on current and future awards. - Delays in the University receiving payments or sponsor’s refusal to pay outstanding
invoices. - Sponsor designation of the University as a high-risk awardee. - The loss of external funding from that sponsor, not only to the individuals involved
but to other University investigators as well. Lastly, federal sponsors have become much more reactive to technical reporting non-compliance.
See NSF’s recentNotice # 148 sent to Presidents of Universities and Colleges and Heads of Other National Science Foundation Grantee Organizations requesting their assistance in improving their institution's compliance with NSF
project reporting requirements. It’s important to note that failure to submit timely reports will delay NSF review and processing of pending proposals
and processing of additional funding and administrative actions for all identified
PIs and co-PIs on an NSF award. NIH takes a similar stand on delinquent reporting where the closeout of an award in such delinquent manner is a serious action that may result
in a future enforcement action, such as withholding of support on another award based
on reporting non-compliance. Lastly, AFOSR has released a memo outlining that failure to address and resolve expenditure rates (e.g. expend grant funding in substantial
amounts throughout the year) and/or reporting problems could result in limited or
no additional funding for grantees to include not fully funding annual award increments
or contingent option years. Please refer to the Guidance and FAQs webpage for additional information on what a PI should do if due dates change or if due dates
are not listed in the award, if the PI is no longer required to provide a written report by the sponsor according to the
award schedule or if the reporting conditions have been modified by the sponsor, if
a PI can’t meet technical report deadlines, and much more. For any questions, please contact the Office of Sponsored Programs at osp@stonybrook.edu. Introduction The RPPR is used by the NIH to gauge the progress of funded projects and is prepared
by the PI and must be reviewed and submitted by the OSP AOR. Only the project director/principal
investigator (PD/PI) or their PD/PI delegate can initiate RPPRs in eRA Commons. For
multi-PD/PI grants, only the Contact PI or the Contact PD/PI’s delegate can initiate
the RPPR. The Office of Sponsored Programs often receives questions from PI’s while drafting
their RPPR’s and to address the most common inquiries, we offer the following information
and TIPS: Helpful links Types of Reports Due Dates Introduction Progress and outcomes reports are used by the National Science Foundation (NSF) to
gauge the progress of NSF funded projects. At this time, the reports can only be initiated,
prepared and submitted by the Project Director (PD)/Principal Investigator (PI) in
Research.gov. The NSF requires progress reports for all financial assistance awards,
including grants and cooperative agreements and utilizes the data from these reports
to track and assess project progress and outcomes, identify issues within specific
projects, fulfill legal obligations, and provide information to the public. The Office of Sponsored Programs often receives questions from PI’s while drafting
their progress reports. To address the most common inquiries, we offer the following
information and TIPS: Helpful links Types of Reports Due Dates Project reports must be submitted electronically at least 90 days before the end of the current reporting budget period. For continuing grants, failure to
submit reports on time may result in delays in processing funding increments. Note
that the date listed in Research .gov is the date the report becomes overdue. By submitting at least 30 days before that overdue date, the PO has sufficient time to review and approve the report.
Be aware that reports submitted late will delay the processing of funding increments
and other administrative actions; including, but not limited to, no-cost extensions.
This may also have an impact on other NSF awards or proposals the PI and Co-PI’s are
listed on as well as any other Federal grants or proposals they are part of since
non-compliant reporting data is shared across these agencies. Note that all Annual Project Reports for each reporting period must be completed before
submitting the Final Project Report. 120 days from the period of performance end date but again, it is recommended that
it be submitted at least 30 days before that end date to allow the PO sufficient time to review and approve the report. Project Outcomes Reports (PORs) apply to all Standard Grants, Continuing Grants, and
Cooperative Agreements. This report provides a concise summary, designed for the public,
outlining the nature and outcomes of the project. Unless otherwise stated in the grant,
PORs must be submitted electronically through Research.gov no later than 120 days after the grant's end date. Quick TIPS & Best Practices:
Financial Reports (FFR, SF 425, quarterly financial disclosure, cumulative invoices) are and must be prepared, endorsed and submitted to the sponsors by the Office of Grants Management.
The form and type of submission are outlined by the sponsor per the terms and conditions
of the award. Some sponsors require periodic reports to contain both technical and
financial information. In these limited situations, you should coordinate with your
assigned OGM Sponsored Award Analyst to obtain updated financial information before submitting the combined report.
Intellectual Property Partners is responsible for the patent and inventions reports.
A property report is not required on all awards but when it is, the Office of Grants
Management is responsible for completing all annual and final property reports that are required
by and submitted to the sponsor.
Award closeouts generally require that a series of final reports be submitted to the
project's sponsor. It is essential that these be prepared and sent on time. The terms
and conditions of the award will specify what should be sent, when and to whom. If
you have any questions about the terms or the process, feel free to contact your OSP
representative.
Closeout Requirements
Closeout Responsibilities
Technical Reporting Procedures
Post Award Management - Financial OGM
Post Award Financial Management
Managing a sponsored project involves adhering to specific policies and procedures. In this section, you’ll find guidance for the financial post-award management including: financial transacting, financial reporting and monitoring, documenting personnel costs (effort reporting), receivables management, project closeout, and audit. Post award financial functions are managed by OGM.
Managing a sponsored project involves adhering to specific policies and procedures. In this section, you’ll find guidance for the financial post-award management including: financial transacting, financial reporting and monitoring, documenting personnel costs (effort reporting), receivables management, project closeout, and audit. Post award financial functions are managed by OGM.
Cash advances are available to project directors under certain conditions to aid in the conduct of their grant activities. Advances can be used for field trip expenses, human subject payments and the purchase of materials and supplies. Funds can be advanced to cover anticipated needs for up to a 90 day period and must be reconciled (accounted for) with original receipts within that time frame. To be eligible for these funds project director's must take personal responsibility for their use in accordance with sponsor guidelines.
Contact OGM for detailed procedures on obtaining and using cash advances.
TITLE 2—Grants and Agreements
PART 200—UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS
Access
http://www.rfsuny.org/Information-For/Online-Tools-/Certify-Your-Effort-eCRT/
Login using your NetID and password
About
Effort Certification and Reporting Technology (ECRT)—eliminates the need for signing paper copies of your effort statement. The benefits of this tool include:
- No paper forms to sign and route
- Just a few clicks to complete your effort certification
- Access your information anytime and anywhere you have Internet access—mobile devices too
- View even more information about your effort and sponsored awards:
- Detailed payroll transactions
- The dollar amounts behind the effort percentages
- Staff charging effort to your awards
- The amount of effort you committed to each award
Guidance Documents
Introduction to the Effort Reporting Electronic Tool
How To Certify My Effort Statement
How To Certify the Effort of My Staff
How to Certify the Effort of Multiple Staff
Questions
Email effortreporting@stonybrook.edu or call 631-632-6038
The Research Foundation's Equipment Floater Policy is an all-risk policy that provides
coverage on equipment (purchased with or without sponsor funds, or on loan from another
institution but used for sponsored projects) against loss by specified external causes
anywhere in the world. Since the University has no other funding source to cover the
damages to or loss of equipment, this is the only vehicle for protecting that equipment.
Premiums
The annual premium rate is: US$ 1.43/ per $100.00 of value
Example: A $1,000.00 piece of equipment will cost $14.30 to insure for a one year period.
Actual premiums are calculated by the OGM staff.
Insurance may be renewed during each new budget period.
Claims and Deductible
Settlement of claims is based on the REPLACEMENT VALUE of the lost or damaged equipment. There is a $1000.00 deductible for each claim.
Should an insurance claim become necessary, contact your SAA in OGM at ogm_ovpr @stonybrook.edu , to review the procedure for documenting the loss.
Insurance Application Procedures
-
Complete a RF Purchase Requisition made out to "AMSURE" for the purchase of insurance.
-
Complete the Insurance Application / Floater Formfor each item being insured.
-
Provide a copy of the Purchase Orders the equipment was originally purchased on to verify value.
-
Send to ogm_ovpr@stonybrook.edu You will receive a confirmation email with the exact premium charged to your account.
-
Upon approval, the documentation is sent to Accounts Payable and is then sent with the check to AMSURE.
There are special financial parameters for involving independent contractors in research
as they are paid through contractual agreements.
About
Consultants are assumed to be Independent Contractors with defined tasks and benchmarks.
- They may not have a continuing involvement in a project and should not require significant supervision.
- Consultants are neither employees nor Fellows.
- They are paid through contractual agreements in which the services they provide are detailed.
- Since their relationship to a project is contractual, the selection of specific consultants is governed by processes more like the purchase of goods and services than the process by which employees are hired, or Fellows appointed.
Consultants understand the following conditions describing their relationship with The Research Foundation of the State University of New York:
- Not eligible to file for, or collect unemployment benefits,
- Not eligible for Worker’s Compensation coverage,
- Solely responsible for complying with all federal, state and local requirements regarding reporting and paying taxes,
- Required to assign all right, title, and interest in the data or material produced as a result of project activities to The Research Foundation of the State of New York, and prohibited from publishing, permitting to be published, or distributing any information concerning the results or conclusions of the data or material produced during or towards project activities. These are considered “works for hire” and as such are the property of The Research Foundation of the State of New York.
- Able to retain ownership of intellectual property included in the deliverables to the extent that s/he will have independently developed the intellectual property without Research Foundation financial support. With respect to such property, s/he agrees to grant The Research Foundation of the State of New York a royalty fee, non-exclusive license to use such intellectual property for purposes consistent with The Research Foundation’s obligations under the grant or contract that funds this project.
- His/her engagement as an Independent Contractor with The Research Foundation may be canceled by the Foundation upon 30-days written notice.
The IRS uses a series of 20 Factors of the “Common Law Test”to determine whether an individual or group of individuals meets the legal requirement
to be considered a consultant. Campus Independent Contractor Guide
What can happen if an independent contractor is misclassified?
If the employer, The Research Foundation for SUNY, unintentionally fails to withhold income taxes for the independent contractor who should have been classified as an employee, the employer’s liability for those taxes will be determined along with penalties.
If someone, or an entity, is misclassified as an independent contractor, charges will
be moved from the independent contractor category to salary & wage category on the
grant; the grant will be charged for the fringe benefit rate relating to the salary
& wages; and The Research Foundation, and in turn, the principal investigator/project
director (PI/PD), will be responsible for any penalties resulting from misclassification.
How will a misclassification be detected?
- IRS or NYS income tax audit
- Individual applies for Unemployment
- Individual applies for Disability or Worker’s Compensation
- Individual completes and submits form SS-8 to IRS
- Research Foundation Internal Audit
Recent changes in IRS regulations governing payments and related income tax withholding to non-resident aliens has caused an additional administrative burden to be placed on campus departments.
Care must be taken to ensure that non-resident aliens are eligible to receive payments for work performed in this country (based on Immigration and Naturalization Service regulations) and that if eligible for payment, can legally be exempt from the 30% federal withholding tax.
If you are planning such an engagement and are not familiar with these requirements, it is important that you contact your Grants Specialist prior to engaging the consultant. Certain essential documents can only be obtained when the consultant/lecturer first enters the United States.
| Twenty Questions | Explanation |
| 1. Compliance with instructions | Employees must comply with another person's instructions on when, where, and how the work is performed. In a true independent contractor relationship, the only control to which the contractor is subject is the result. |
| 2. Training required | Independent contractors are not normally trained but rather are hired for their expertise in a field. |
| 3. Integration of services into business operations | Integration of services into business operations |
| 4. Services rendered personally | Employees personally render the services, while contractors may delegate such work to others |
| 5. Hiring, supervising and paying assistants | Usually individuals who perform all these functions are treated as independent contractors. |
| 6. Continuing relationship | Employees are usually hired for an ongoing period, while a contractor's work ends when the job ends. |
| 7. Set hours of work | Employees usually must adhere to a work schedule established by the employer |
| 8. Full-time required | Generally, employees work full-time for an employer, while independent contractors work when and for whom they choose. |
| 9. Performing work on the employer's premise | Those working at the employer's site may be viewed as employees. |
| 10. Services performed in order or sequence set | Persons told to perform work in a certain sequence generally are considered employees. |
| 11. Oral or written reports | Employees are more likely to be required to submit regular reports to the employer. |
| 12. Payment by hour, week, month | Typically, employees are paid on a regular basis, while independent contractors are compensated by the job or on a lump-sum or straight commission basis. |
| 13. Payment of business and/or travel expenses | Employer payments of a person's work-related travel expenses generally indicates employee status. |
| 14. Furnishing of tools and materials | Employees, not individual contractors, are generally provided with supplies. |
| 15. Significant investment | Individuals who have a significant personal investment in the facilities they use for work are normally independent contractors. |
| 16. Realization of profit or loss | Unlike employees, independent contractors realize a profit or loss based on their success in performing a service. |
| 17. Working for more than one firm at a time | Individuals who perform services for a number of employers are usually independent contractors. |
| 18. Making services available to the general public | Individuals who regularly make their services available to the general public are usually treated as independent contractors. |
| 19. Right to discharge | Employees can be fired, while independent contractors cannot be discharged if they fulfill contract specifications. |
| 20. Right to terminate relationship without incurring liability | An employee can terminate his employment relationship with his employer at any time, whereas an independent contractor may be liable for breach of contract for leaving work unfinished. |
- Non-wage support payment for a person engaged in a nonacademic vocational or secondary school education and training program administered by the Research Foundation.
- In many cases, a participant stipend is paid from summer outreach and enrichment programs.
- Typically, there is an expectation that the participant be present at program related event(s).
- Participant Stipend Form
- Non-citizens - requires 30% withholding
- For U.S. citizens - a 1099 is issued for payments exceeding the $600 threshold within a calendar year
The purchase of goods and services in support of sponsored projects comprises the
second largest activity.
The two major procurement categories are
- Supplies
- Equipment
To make a purchase, a signed Purchase Requisition must be sent to OGM. Purchase Requisitions are reviewed by OGM for consistency with
general regulations (e.g., Cost Accounting Standards) and sponsor specific regulations. See also policy on office supplies.
Equipment Purchase
For The Research Foundation, equipment includes items with acquisition costs of $5,000
or more and an expected useful lifetime of two (2) years or more. The identification
of an item as equipment subjects the item to an inventory requirement. Equipment inventory
is managed by Property Control and is subject to federal audit. The Research Foundation offers casualty and theft insurance on research equipment, the costs of which are allowed on most sponsored projects.
Additional information can be found in the RF Equipment Insurance Guide.
Procurement Website
The procurement website has more information on purchasing goods.
By accepting external funding, our institution agrees to comply with the terms and conditions associated with the awards. It is a shared responsibility of the PIs, departmental business/administrative offices and central offices. Generally, grants, contracts, cooperative agreements and other funding mechanisms may require some or all of the following reporting: technical, financial, patent and invention, and property inventory for both purchased and sponsor supplied equipment. While the Offices of Grants Management and Intellectual Property Partners are responsible for the financial reports (e.g. FFR, SF 425, quarterly financial disclosure, cumulative invoices), property inventory and patent and inventions reports, PIs are required to understand and comply with the technical/programmatic reporting requirements of their awards, which involves becoming familiar with reporting formats, templates and any online submission portals. These reports may be referred to by the sponsor as: RPPR (Research Performance Progress Report), Technical Report, Performance Report, Project Report.
In some cases (e.g. NIH RPPRs), the PI and the Office of Sponsored Programs (“OSP”) work together to complete and submit the report. In others, PIs are encouraged to discuss and share the report with OSP prior to submission (e.g. NSF).
Outlined in his section are the types of reports that may be required and the individual
or department that is responsible for the submission of these reports.
Financial Reports (FFR, SF 425, quarterly financial disclosure, cumulative invoices) are and must be prepared, endorsed and submitted to the sponsors by the Office of Grants Management. The form and type of submission are outlined by the sponsor per the terms and conditions of the award. Some sponsors require periodic reports to contain both technical and financial information. In these limited situations, you should coordinate with your assigned OGM Sponsored Award Analyst to obtain updated financial information before submitting the combined report.
Not all budgets require financial reporting. In particular, for budgets that are invoiced, the invoice transaction detail may serve the same function as a financial report for the sponsor, allowing them to monitor the allowability of expenditures.
If a sponsor contacts you about financial reporting, please forward their email to ogm@stonybrook.edu.
If you have questions or concerns about a specific budget’s financial reporting, please contact your OGM Sponsored Award Analyst.
Intellectual Property Partners is responsible for the patent and inventions reports.
Agencies generally require institutional signature or submission in sponsor systems for both positive and negative invention statements. Contact Maureen Case in IPP at maureen.case@stonybrook.edu
A property report is not required on all awards but when it is, the Office of Grants Management is responsible for completing all annual and final property reports that are required by and submitted to the sponsor.
If you have questions about whether an annual Government property inventory and report are needed for your award, contact your OGM Grants Analyst. General property questions may also be sent to ogm@stonybrook.edu.
Award closeouts generally require that a series of final reports be submitted to the project's sponsor. It is essential that these be prepared and sent on time. The terms and conditions of the award will specify what should be sent, when and to whom. If you have any questions about the terms or the process, feel free to contact your OSP representative.
OSP and OGM have developed a checklist in an effort to assist Principal Investigators
transition activities prior to termination of their funded awards.
Closeout Requirements
Sponsors generally require a basic set of reports in order to close an award. It is important to complete all the requirements and it is important to do so in the time frame stipulated by the sponsor. The closeout documentation and the time frame for submission are stated in the terms and conditions of the award or contract. The usual terms require that the following reports be submitted within 30, 60 or 90 days of expiration of the award:
- Final technical report
- Final financial report
- Final inventions report
- Final property report.
Non-compliance in this regard can lead to debarment of the PI from receiving subsequent
grants from the sponsor. Ultimately, it can even lead to the debarment of the University
from receiving grants from the sponsor because the University is held responsible
for all required closeout documents.
Closeout Responsibilities
The Principal Investigator/Project Director (PI)
- Writes and submits a final report to the sponsor in the time required by the terms of the grant
- Identifies all expenses properly allocable to the grant and remove any expenses that are incorrect or exceed the amount of the grant
- If inventions were disclosed on the project, coordinates with Intellectual Property Partners (IPP) to ensure that a complete final invention report is submitted
- If the sponsor loaned equipment, coordinates with the OGM for final disposition of the equipment
- Insures that all project expenses are properly identified and that the fund balance is not overdrawn.
OGM
- Prepares and submits the final financial report to the sponsor and returns any unspent funds
- Prepares and submits a final equipment report if required.
IPP
- Prepares the final inventions report in coordination with the PI and provides the information to the sponsor and OSP.
Each award has specific requirements for the content and submission of technical reports. We recommend contacting your OSP Specialist who can provide you with guidance specific to your award from how to submit (ie Sponsor portal or Email to PO) and respond to questions regarding content and/or related to the sponsor portal (ie NIH eRA Commons, NSF Research.gov, NASA, NOAA Grants Online, etc). Technical report content can include sections such as Accomplishments, Products, Participants, Impact, Changes/Problems, Special Reporting Requirements, and Budget/Financial. Accurate reporting is essential to ensuring you as PI and the Institution is compliant with all Sponsor policies and procedures. Inaccurate reporting can lead to such measures as the Sponsor determining that we have been non-compliant and ceasing funding of the individual award and depending on the severity of the non-compliance, further repercussions will ensue. Key sections for compliance include (1) Participants (complete and accurate effort reporting of all Sr/Key Persons for that budget year which should align with the approved level of effort for that year both by SBU and the Sponsor); (2) Changes (reduction of PI effort (a reminder that a myResearch Award Modification is needed prior to any change in effort and Sponsor Approval when applicable); addition of Sr/Key Persons (please speak to your OSP Specialist to determine whether Sponsor approval is needed and if a myResearch Award Modification is needed); Other Support (typically you will see a question similar to "Has there been a change in the active other support of senior/key personnel since the last reporting period?" - please refer to Sponsor specific guidance and SBU policies), and (3) Special Reporting Requirements (ie Is it anticipated that an estimated unobligated balance (including prior year carryover) will be greater than 25% of the current year’s total approved budget? If yes, provide the estimated unobligated balance.)
Frequently Asked Questions
What should I do if due dates change?
OSP recognizes that technical reporting due dates may change during the course of a sponsored project. If you receive a due date change notification from a sponsor, you are responsible to promptly inform OSP at osp@stonybrook.edu so our records can be updated. This will avoid unnecessary escalations.
What should I do if due dates are not listed in the award?
Certain sponsors do not list technical report due dates in the award document. They may instead provide the due dates to you at a later date. If you do not have the technical report due dates, you should contact your Program Manager / Technical Contact for more information. Once you have the dates, promptly inform OSP at osp@stonybrook.edu so our records can be updated.
What should I do if I am no longer required to provide a written report by the sponsor according to the award schedule or if the reporting conditions have been modified by the sponsor?
Please provide the sponsor’s updated guidance and/or waiver in response to this email so that our records can be updated.
What should I do if I recently completed this reporting via informal communication with the sponsor or if the sponsor is not expending a formal report from me?
You must provide OSP Provide proof of sponsor’s consent in order to update the reporting records.
What should I do if I cannot meet technical report deadlines?
If you cannot meet technical report deadlines, you should first contact your Program Manager / Technical Contact to see if it’s possible to obtain a deadline extension. Your Program Manager / Technical Contact is not required, or may not have authority, to grant an extension. If the PI provides suitable justification, OSP can also contact the sponsor to request an extension on the PIs behalf.
If the extension request is unsuccessful, promptly contact your Department Chair and/or Dean. They may be aware of other resources available (e.g., graduate students) to assist you.
Do I need to submit technical reports if I have requested a no-cost extension?
Yes. Unless you have written confirmation from your Program Manager / Technical Contact that your report is not due, you must submit your report by the existing deadline.
For example, National Science Foundation has advised: “A ‘no cost extension’ adds time to an award, but does not relieve the awardee of reporting requirements. Annual reports are still due every 12 months. When the award finally does expire, the final report and project outcomes report are both due within 120 days.” See, e.g., Dear Colleague Letter No. NSF 16-040.
What constitutes “proof” I have submitted my technical report?
The automated email reminders described above ask that you submit a copy of your technical report in myResearch. Other acceptable methods include (i) copying osp@stonybrook.edu when you submit your report via email; and (ii) forwarding a copy of a confirmation you receive from an online portal after your submission. Please note that merely stating you have submitted your report is not sufficient. OSP needs written information from an independently verifiable source, as OSP may be required to provide this information to our external auditors.
Do I submit financial reports to sponsors?
All financial reports (FFR, SF 425, quarterly financial disclosure, cumulative invoices) MUST be prepared, endorsed and submitted by the Office of Grants Management. Some sponsors require periodic reports to contain both technical and financial information. In these limited situations, you should coordinate with your assigned OGM Sponsored Award Analyst to obtain updated financial information before submitting the combined report.
Where can I find additional general references and guidance?
NSF
The NSF has published memo number NSF 16-040, Meeting NSF's Technical Reporting Requirements. The memo contains answers to frequently asked questions and links to additional resources and information regarding NSF's reporting requirements. Principal Investigator submits directly. Frequency: Annual and Final. Submission website: https://research.gov
Other Sponsors - coming soon
PIs are required to understand and comply with the technical/programmatic reporting requirements of their awards, which involves becoming familiar with reporting formats, templates and any online submission portals. These reports may be referred to by the sponsor as: RPPR (Research Performance Progress Report), Technical Report, Performance Report, Project Report. In some cases (e.g. NIH RPPRs), the PI and the Office of Sponsored Programs (“OSP”) work together to complete and submit the report. In others, PIs are encouraged to discuss and share the report with OSP prior to submission (e.g. NSF).
OSP supports PIs with their technical reporting obligations by sending them automated email reminders from ovpr_myresearchgrants@stonybrook.edu 60, 30 days before technical reports are due, as well as on the due date. This applies to awards set up in myResearch after February 2020. The email subject line contains the words IMPORTANT ACTION REQUIRED REGARDING TECHNICAL REPORTING. PIs are encouraged to open these emails and follow the instructions. Here’s an example notification:
IMPORTANT ACTION REQUIRED REGARDING TECHNICAL REPORTING - PLEASE READ AND RESPOND ACCORDINGLY
- If you are no longer required to provide a written report by the sponsor according to the award schedule or if the reporting conditions have been modified by the sponsor, please provide the sponsor’s updated guidance and/or waiver in response to this email so that our records can be updated.
- If you have recently completed this reporting via informal communication with the sponsor, respond to this email so that our records can be updated. Provide proof of sponsor’s consent.
- If you have not completed the reporting, do so as soon as possible to avoid restrictive actions on your award and possible Sponsor action against the institution. Directions on how to submit are below.
- If you have completed the reporting through the sponsor portal, you still need to tag it as completed under the Manage Deliverables activity of your Award in myResearch. Copies of NIH and NSF reports can be uploaded but it is not mandatory.
Note that for awards set up prior to February 2020, the email notification to PIs will be from Razeema Sahib, Account Establishment & Maintenance Unit. A copy of the report needs to be provided to OSP via email, according to the email instructions.
If a PI cannot submit a technical report by a required due date, s/he should contact the sponsor, before the due date, and copy OSP, requesting an extension. If the PI provides suitable justification, OSP can also contact the sponsor to request an extension on the PIs behalf.
If a PI has not submitted a technical/performance report and provided OSP proof of submission prior to the due date, OSP will take the following corrective actions:
- When a technical report is 30 days overdue, the PI will receive an automated notification from ovpr_myresearchgrants@stonybrook.edu 30 days AFTER the technical reports are due. The email subject line contains the words TECHNICAL REPORTING NON-COMPLIANCE - IMMEDIATE ACTION REQUIRED. PIs are required to open these emails and follow the instructions.
- When a technical report is 45 days overdue, it is considered delinquent. The PI will receive an email from ovpr_myresearchgrants@stonybrook.edu with the subject line: From the desk of Alina Azzam-Stroia, Sr. Director Office of Sponsored Programs: DELINQUENT REPORT – YOUR AWARDS WILL BE FROZEN IF IMMEDIATE ACTION IS NOT TAKEN WITHIN 5 BUSINESS DAYS - PLEASE READ AND RESPOND PROMPTLY. If action is not taken as instructed, the PI will become ineligible to submit new proposals as a PI or CoPI until the technical report has been submitted, and all of the PI’s awards will be placed on hold in the financial system. OSP will place a “hold” on the setup of any new accounts for the PI. New accounts include, but are not limited to, new awards, continuations, and risk accounts. If a CoPI has a separate account and has a seriously delinquent report, this procedure will also apply. The Chair, Center Director, and/or Dean will be copied on the delinquent email correspondence so they are aware of reporting noncompliance and can become actively involved in resolving the problem. This procedure will continue until the reports are submitted. All such actions will be in full consultation with the Vice President for Research and/or the Associate Vice President for Research and will occur with the support of the VPR office.
Delinquent reporting is a significant issue and can negatively impact payment on individual awards and future funding for the entire university, and it can damage SBU’s reputation. Furthermore, audits, including our annual A-133 audit, encompass reporting compliance, so federal penalties and other consequences due to noncompliance are real possibilities. Among the actions sponsors can take when reports are not received by the deadline are the following:
- The loss of expanded authorities on current and future awards.
- Delays in the University receiving payments or sponsor’s refusal to pay outstanding invoices.
- Sponsor designation of the University as a high-risk awardee.
- The loss of external funding from that sponsor, not only to the individuals involved but to other University investigators as well.
Lastly, federal sponsors have become much more reactive to technical reporting non-compliance. See NSF’s recentNotice # 148 sent to Presidents of Universities and Colleges and Heads of Other National Science Foundation Grantee Organizations requesting their assistance in improving their institution's compliance with NSF project reporting requirements. It’s important to note that failure to submit timely reports will delay NSF review and processing of pending proposals and processing of additional funding and administrative actions for all identified PIs and co-PIs on an NSF award. NIH takes a similar stand on delinquent reporting where the closeout of an award in such delinquent manner is a serious action that may result in a future enforcement action, such as withholding of support on another award based on reporting non-compliance. Lastly, AFOSR has released a memo outlining that failure to address and resolve expenditure rates (e.g. expend grant funding in substantial amounts throughout the year) and/or reporting problems could result in limited or no additional funding for grantees to include not fully funding annual award increments or contingent option years.
Please refer to the Guidance and FAQs webpage for additional information on what a PI should do if due dates change or if due dates are not listed in the award, if the PI is no longer required to provide a written report by the sponsor according to the award schedule or if the reporting conditions have been modified by the sponsor, if a PI can’t meet technical report deadlines, and much more.
For any questions, please contact the Office of Sponsored Programs at osp@stonybrook.edu.