Post-Award Grant Administration

The information below provides a good resource for grant administration, internal policies, compliance, and grant administration contacts in the Harvey Mudd community.

Grant Administration FAQ’s

My program officer notified me that I have been selected to receive an award, may I begin spending on the award before I receive the award letter from the granting agency?

Pre-award costs, 90 calendar days prior to the award or more than 90 calendar days, require prior approval of the Federal awarding agency. All pre-award costs are incurred at the institution’s risk (i.e., the Federal awarding agency is under no obligation to reimburse such costs if for any reason the recipient does not receive an award or if the award is less than anticipated and inadequate to cover such costs). Therefore, the Department Chair, Dean of Faculty, and Grants Accountant must approve pre-award costs in advance of contacting the granting agency for approval.

I have received a federal grant award, can I transfer costs from one budget line item to another?

Yes, in most cases. Some federal agencies may require prior approval of budget revision to certain budget categories or circumstances:

  • The transfer of funds allotted for training allowances (direct payment to trainees) to other categories of
  • Unless described in the application and funded in the approved awards, the subaward, transfer or contracting out of any work under an award, may require prior approval. This does not apply to the purchase of supplies, material, equipment or general support
  • The Federal awarding agency may, at its option, restrict the transfer of funds among direct cost categories or programs, functions and activities for awards in which the Federal share of the project exceeds $100,000 and the cumulative amount of such transfers exceeds or is expected to exceed 10% of the total budget as last approved by the Federal awarding (NSF does not restrict this type of transfer).

The best way to acquire assistance for a budget revision is to contact Arlene Chubbuck in the Business Affairs Office at 909.607.0352 or by email at achubbuck@hmc.edu.

Can I transfer funds from my federal grant to another grant if the project is related?

No, you may not transfer funds from one grant to another. You may process a cost transfer request, moving the expense from one grant to another to correct an error. Please be aware that cost transfers are one of the highly tested transactions during an audit.

My grant is expiring soon, but the project will not be complete by this time. May I ask for an extension?

Most granting agencies allow a one year no-cost extension. You may authorize a one-time extension of the expiration date of the grant of up to 12 months if additional time beyond the established expiration date is required to assure adequate completion of the original scope of work within the funds already made available. You must notify the Federal awarding agency in writing with the supporting reasons and revised expiration date at least 10 days before the expiration date specified in the award. This one-time extension may not be exercised merely for the purpose of using the unliquidated balances. Grantees are not authorized to extend an award that contains a zero balance.

I need to purchase equipment under my federal grant, are there any inventory tracking requirements?

Yes, there are inventory tracking requirements if the equipment cost is $5,000 or more. Equipment inventory records should include the date of purchase, amount of purchase (including sales tax, delivery charges and/or installation costs), physical location of equipment (building and room number), the model/serial number of the equipment, the account number(s), and a unique departmental ID tag number (this should also be attached to the equipment). All documentation of equipment purchases on the inventory log must be kept until the disposal of the equipment. Please contact the Business Affairs Office when disposing of College equipment (either capitalized or non-capitalized) for proper accounting. If disposal consists of selling the equipment, sales tax may apply.

I am booking an international flight that will be charged to my federal grant, are there any restrictions?

Yes, federal grant recipients are required to abide by the provisions of the Fly American Act. The Fly American Act requires that foreign air travel is performed on U.S. flag air carriers, unless specific circumstances qualify as an exception. If, these regulations are not met, the foreign travel will not be reimbursable by a federally funded grant/contract. For more information about the Fly American Act and qualifying exceptions, please visit the Grant Administration page on the Dean of Faculty website.

How can I monitor the expenses being charged to my grant?

Faculty members are given access to the online financial reporting tool called CUConnect. CUConnect allows users to view their budget in comparison to their expenses. Users can click on a particular expense and drill down to the document level to view supporting documentation of that expense. Grant questions regarding budget vs. actual or CUConnect questions can be directed to Heather Clark in the Business Affairs Office at 909.607.0352 or by email at achubbuck@hmc.edu.

I’ve heard that in order to pay a vendor for goods or services with federal funds from a grant, the vendor must be verified to ensure that they are not debarred or suspended from receiving federal funds, is this true?

Yes, when purchasing goods or services using federal funds, the Principal Investigator must ensure that the vendor selected for providing goods or services for the grant is not suspended or debarred from receiving federally sourced funds and must provide proof of verification. Vendors can be verified by going to the Excluded Parties website: https://www.epls.gov/. Proof of verification consists of printing a screen shot of the web page when the search is performed before the order is place. The verification must be submitted with the vendor invoice when requesting payment for the vendor.

Sponsor Post-Award Resources

National Science Foundation (NSF)

The Award and Administration Guide(AAG) (Part II of the NSF Proposal & Award Policies & Procedures Guide) sets forth NSF policies regarding the award and administration of grants and cooperative agreements and implements Office of Management and Budget (OMB) Circular A-110 and Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations.

The Grant General Conditions, Research Terms and Conditions, Cooperative Agreement Conditions and Special Conditions pages provide the full text of the terms and conditions used to manage NSF grants and cooperative agreements. Topics covered include awardee responsibilities, Federal requirements, pre-award costs, no-cost extensions, significant project changes, travel, allowable costs, project reports, final report requirements, and more.

National Institutes of Health (NIH)

The National Institutes of Health Grants Policy Statement (NIHGPS) is intended to make available to NIH grantees, in a single document, the policy requirements that serve as the terms and conditions of NIH grant awards. This document also is designed to be useful to those interested in NIH grants by providing information about NIH—its organization, its staff, and its grants process. This version includes many links within the document as well as links to some web resources outside of this document. Users are strongly encouraged to use the on-line version of this document to benefit from these links.

U.S. Department of Education

Title 34 of the Code of Federal Regulations (CFR), which pertains to the U.S. Department of Education and related Federal entities, is composed of several hundred parts printed in three volumes. Parts 74-99 of that title are collectively known as the Education Department General Administrative Regulations (EDGAR). These parts contain regulations for administering discretionary and formula grants awarded by the Department.

HMC Post-Award Polices

There are several internal policies relating to federal grants that faculty members should know.

Allowable/Unallowable Costs (PDF)

Determining whether costs are allowable and should be charged to a federal grant or contract is important.

Budget Revision (PDF)

P.I.’s may find it necessary to revise their budget for their grant or contract. Some situations require prior agency approval.

Conflict of Interest

Harvey Mudd College requires the disclosure of financial interest in research or other activities supported by College-sponsored or external grant sources.

Cost Transfers (PDF)

When the need for transferring costs between accounts involving a federally funded grant or contract is necessary, care should be taken that any transfer of costs into or out of federally funded accounts are handled appropriately.

Equipment Inventory Requirements (PDF)

Maintaining an inventory of equipment costing $5,000 or more that is purchased with federal funds is required

Human Subject Use (PDF)

The Institutional Review Board protects the rights and welfare of humans recruited to participate in research activities conducted under the auspices of the Claremont Graduate University and Harvey Mudd College.

For more information about the Institutional Review Board (IRB), please visit the IRB website.

Intellectual Property (PDF)

All faculty members and students of Harvey Mudd College have full ownership of any intellectual property that they produce during the course of their involvement with the college, except when external sponsorship of the work requires the assignment elsewhere.

Scientific Conduct (PDF)

There are certain standards within the scientific community, which are essential to ensure the quality and integrity of research.

Suspension and Debarment (PDF)

When purchasing goods or services using federal funds, it is necessary to verify that the vendor is not suspended or debarred from receiving federal funds.

Time and Effort Certification

Salaries on federal grants typically make up the majority of expenditures and special certifications must be completed to satisfy federal regulations.

Compliance

Compliance is an important subject when it comes to grant administration. Faculty will find the following compliance topics to be of particular interest.

The Office of Management and Budget

The Office of Management and Budget (OMB) oversees the activities of Federal Agencies in the United States. The OMB issues circulars to provide guidance for Federal Agencies and Grantees to administer Federal awards. Recently the OMB combined several Federal circulars into a single document called the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, generally referred to as the Uniform Guidance or 2 CFR 200. The following subparts of the Uniform Guidance pertains to the Grantee’s administration and compliance of Federal awards:

The Uniform Guidance is applicable to new and incremental Federal Awards issued on or after December 26, 2014. The College continues to follow guidance under OMB Circulars A-21 – Cost Principles for Educational Institutions, A-110 – Uniform Administrative Requirements for Grants and Agreements, and A-133 – Audits of States, Local Governments and Non-Profit Organizations, where applicable. The College had elected to defer the procurement standards of Uniform Guidance 2 CFR § 200, Subpart D, until July 1, 2018.

Catalog of Federal Domestic Assistance

The Catalog of Federal Domestic Assistance (CFDA) is a government-wide compendium of Federal programs, projects, services, and activities that provide assistance or benefits to the American public. It contains financial and non-financial assistance programs administered by departments and establishments of the Federal government.

Faculty who have received federal assistance or are interested in applying for federal assistance should review the applicable CFDA for specific requirements of the program and related audit information. See Catalog of Federal Domestic Assistance page for more information.

Federal Travel Regulation/Fly American Act

The Federal Travel Regulation (FTR) implements statutory requirements and Executive branch policies for travel by individuals authorized to travel at government expense. See Fly American Act for more information.

Export Controls

The United States established export controls to protect the national security and foreign policy interests. Export controls govern the shipment, transmission, or transfer of certain regulated items, information, or software to foreign persons or entities.

When export control regulations apply, the approval from the U.S. Government may be necessary. In these situations, such as when fundamental research safe harbor is unavailable, an export license must be obtained to ship or share of regulated/controlled items, information or software. See Export Controls for more information.