Award management includes all post-award activities that occur between the time an award/account is established in Wayne State's financial system and when the closeout process begins for sponsored program accounts. All SPA groups are involved in the management of your award. Visit the SPA Directory page for specific information about each SPA group and their contact information.
- Requests for Agency Prior Approvals
Prior approval requirements vary by agency. It is recommended to contact your SPA GCO for specific questions about prior approvals and for submission of the requests.
Prior approval requests that are not submitted via an online agency system need to be initiated at the SPA level with written communication to the agency Contracting Officer (not Program Officer) signed by the PI. The memo must include the information recommended below. The PI and Department Administrator will be notified when a reply is received from the agency.
For no-cost extensions, the following information should be included in the request, which needs to be signed by the PI.The agreement number; the extended agreement end date; a technical justification as to why the extension is needed; a brief description of what will be done during the extension period; a comment regarding any revision to the scope of work, if applicable.
PI Change Request
The communication from the PI and SPA needs to include the effective date of the change, the new PI's curriculum vitae, and comment if the scope of work is being revised.
Revised Budget Request
The award agreement will specify the restrictions for budget revisions. The signed memo from the PI needs to include why the budget revision is necessary for the project, if the scope of work is being revised, along with the revised budget.
- If effort is reduced more than 25% during this time you will need to seek agency approval of the reduced effort on the project.
- If the request is being submitted after the end date, then you will need to provide an explanation as to why the request is being submitted late.
Agency Specific Guides
Summarize when prior agency approval is necessary for National Institute of Health (NIH) and National Science Foundation (NSF) grants
- Cost Policy
Expenditures on externally funded awards must comply with the more restrictive of policies
- Award specific terms and conditions
- Applies only to a specific award
- Agency terms and conditions
- Applies to all awards funded by a particular sponsor: NIH, NSF, DOE, etc.
- Federal Government requirements
- Applies to all federally funded awards
- The Uniform Guidance (UG) from the Office of Management and Budget (OMB) found at 2 CFR Chapter 1, part 200 (http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title02/2cfr200_main_02.tpl)
- Wayne State University Policies
- Wayne State University Code Annotated (WSUCA)
- University Policies
- Administrative Policies and Procedures Manual (APPM)
In instances of discrepancy between the general provisions and the project terms and conditions of an award, the award provisions should govern. When WSU policy and agency policy differ, the more restrictive policy applies.
Basic Cost Principles
Expenses incurred on sponsored program accounts must be allowable, reasonable, allocable, and consistently treated between a direct cost and something normally treated as an indirect or an F&A cost. In addition, sufficient documentation must be available (attached to transaction, maintained in department, etc.) to demonstrate that the following basic cost principles are met.
- Allowable: The cost must comply with the policies and procedures of WSU, as well as the specific project terms and conditions of the agreement, and be adequately documented; 2 CFR 200.403
- Reasonable: The cost does not exceed that which would be incurred by a prudent person; 2 CFR 200.404
- Allocable: The cost must be allocated to the project(s) in accordance with the benefits received; 2 CFR 200.405
- Consistently Treated: The cost must be accorded consistent treatment; i.e., an expense may not be charged to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the award as an indirect cost; 2 CFR 200.403
Needed, Received, and Used
Auditors focus on expenditures that are incurred close to a project's end date (i.e. is it truly necessary for the project or just using unspent funds). As a result, purchases need to meet a "needed, received and used" principle. Allowable expenditures during the last 3 months of a project period need to affirmatively answer the following questions.
Is the item(s) needed to complete the project objectives?
Was it received by the project end date?
Was it used in support of the project by the project end date?
For example, the Principal Investigator (PI) wants to buy a piece of equipment three months before the end of a project. In addition to meeting the basic considerations of federal cost principles (allowable, reasonable, allocable, and consistently treated), the equipment purchase must also be in accordance with the "needed, received and used" criteria, meaning it is needed to complete the scope of work and will be received and used by project personnel prior to the end date.
Exceptions to the "needed, received and used" principle are publications costs (within the 90 or 120 close-out period) and unique items with specific agency approval.
- Award specific terms and conditions
- Allowable or Unallowable Costs
Expense categories listed below are provided for reference purposes and are not all inclusive.
The following categories provide guidance on when the expense may or may not be allowable on a state or federally funded project, as well as documentation that may be necessary to support the cost.
Costs that are typically unallowable may only be charged to your project account when specifically approved by the awarding agency in the award budget or correspondence from the grants officer.
Advertising and Public Relations
Cost Allowable Unallowable Advertising and public relations costs incurred solely for project purposes X Gifts, souvenirs and costs to promote WSU X Gifts based on custom or given as a thank you X
Examples of advertising and public relations expenses that are typically allowable include:
- Project personnel recruitment
- Program outreach
- Required communication/press releases
- Advertising for disposal of project materials
Cost Allowable Unallowable Alcoholic Beverages X
Alumni Activities and Contributions
Cost Allowable Unallowable Alumni Activities X Contributions/Donations X
- 2 CFR 200.424 (General Provisions: Alumni/ae Activities)
- 2 CFR 200.434 (General Provisions: Contributions and Donations)
Cost Allowable Unallowable Building construction and/or land acquisition (unless it is the purpose of the award) X
Cost Allowable Unallowable Entertainment costs including but not limited to amusement, diversion and social activities X
Exceptions must be listed in the approved budget.
Cost Allowable Unallowable Special purpose equipment used for project activities that has been approved by the agency or was included in the approved budget. X General purpose equipment, buildings, land, or improvements to those items that materially increase the value. X The capitalization of WSU labor costs used to fabricate equipment. X
- The cost of special purpose equipment should be charged to projects in proportion to its anticipated use and should be coded with appropriate equipment object codes.
- In order to avoid duplicate purchases, the Principal Investigator (PI) must provide the following certification. "I certify that this equipment is necessary and will be used for the project charged or in relative proportion to the projects to which the costs will be charged and that similar equipment is not available for use."
- Must be attached to Requisition or Purchase Order
- Labor costs used to fabricate equipment are considered a salary or contractual service cost and will be subject to the appropriate F&A.
- 2 CFR 200.439 (General Provisions: Equipment and Other Capital Expenditures)
- 2 CFR 200.318 (Procurement Standards: General Procurement Standards)
Fines and Penalties
Cost Allowable Unallowable Fines and penalties including late fees on invoices, special handling fees (rush payment fees, etc.) X
Deficits on Other Awards or Contracts
Cost Allowable Unallowable Deficits on other awards including moving expenses from one account to another account due to lack of funds, or because grantor did not pay, etc. X
Cost Allowable Unallowable Maintenance/repair costs of necessary and specific project items X Charges for general department or lab maintenance and repairs X
Cost Allowable Unallowable WSU employee meals when travelling X Meals as part of a project conference X Meals for potenatal project personnel - recruiting X Meals for Non- WSU, non-federal visitors or collaborators X Meals for WSU employee participating in recruitment of non-WSU personnel X WSU personnel meals when not travelling, except as identified below in additional information. X Meal costs for WSU personnel participation in "working" meals X Meals for meetings in which technical information is shared between WSU project personnel only (i.e. lab/staff meetings) X
Additional InformationAs indicated in the chart above, often meal expenses are considered unallowable. If meal expenses are submitted, they will be reviewed for allowability on a case-by-case basis, considering some or all of the following factors:
- Business purpose
- Length of event/meeting
- Location of event/meeting
- Participation of non-WSU employees
- Necessity of the expense
- Agency approved budget
- Agency or award specific guidelines
- 2 CFR 200.463 (General Provisions: Recruiting Costs
- WSU Administrative Policies and Procedures Manual (APPM): 1.3.1. Expense Guidelines
A conference is defined as a meeting, retreat, seminar, symposium, workshop or event whose primary purpose is the dissemination of technical information beyond WSU personnel.
Cost Allowable Unallowable Meeting and conference costs when reasonable and necessary to a project (typically included in approved budget) X Costs associated with meetings and conferences attended by only WSU personnel (not travelling) X
Additional InformationCosts typically associated with a conference/meeting include: facility rental, A/V equipment costs, conference attendee lodging and meals, printing costs. Factors that affect the allowability of a conference/meeting include: business purpose and length and location of event
- Required documentation with conference transactions include: agenda, list of participants and business purpose
- A best practice procedure to document reasonable conference costs is having sign-in sheets for all conference attendees.
- 2 CFR 200.432 (General Provisions: Conferences)
- WSU Administrative Policies and Procedures Manual (APPM): 1.3.1. Expense Guidelines
Membership, Subscription, and Professional Costs
Cost Allowable Unallowable Membership, subscription, and professional activity costs when they directly benefit the sponsored program X WSU's membership in business , technical, and professional organizations X Individual memberships that are in accordance with WSU's Administrative Policies and Procedures Manual (APPM) X
- 2 CFR 200.454 (General Provisions: Memberships, Subscriptions, and Professional Activity Costs)
- WSU Administrative Policies and Procedures Manual (APPM): 1.3.1. Expense Guidelines
Participant Support Costs
Participant Support Costs are costs for participants or trainees (but not employees) in connection with conferences, workshops, or training projects and may include stipends, subsistence allowances, travel costs and registration fees.
Cost Allowable Unallowable Participant support costs that have prior agency approval X Costs related to WSU personnel X
- Participant support costs must be separately identified in the agency approved budget
- This is a restricted budget category, any budget deviations out of this category requires agency approval.
- Exempt from F&A for all federal awarding agencies.
- 2 CFR 200.456 (General Provisions: Participant Support Costs)
- 2 CFR 200.1 (Acronyms & Definitions: Participant Support Costs)
- 2 CFR 200.308 (Revision of Budget and Program Plans)
Personal Use Good or Services
Cost Allowable Unallowable Items used by WSU employees that are project-specific X Personal use of goods and services X
- Examples of good and services that are the responsibility of the employee are GPS used to find a hotel, toiletries, and clothing.
- Examples of items used by employees that are project specific are bug spray in Africa, waders for work in streams, and medical shots required for international travel.
Cost Allowable Unallowable Expenses incurred prior to project start date X
- Many federal agencies, such as NSF and NIH allow for 90-day pre-award spending on grants without prior approval.
- 2 CFR 200.458 (General Provisions: Pre-Award Costs)
- Specific agency guidelines
Cost Allowable Unallowable Professional services when costs are reasonable and necessary to prject objectives X Speaker fees X Honoraria X Lump sum payments without a rate justification X
- 2 CFR 200.459 (General Provisions: Professional Service Costs)
- WSU APPM 1.3.2 Special Payment Auhorization (SPA) 10-102A
Salaries and Wages
Cost Allowable Unallowable Faculty, technical staff and student pay at Institutional Base Salary (IBS) rates X Administrative or clerical salary that is integral to the project or activity, includes individuals who can be specifically identified with the project or activity, are explicitly included in the budget or have prior written approval of the awarding agency, and the costs are not also recovered as indirect cost X Non faculty overtime in compliance with employee contracts and when related to project activities X Lump sum payments without a rate justification X Faculty overload X General administrative and clerical salaries X
- Faculty administrative increment(s) are included in IBS, but Health Care Service Component (HSRC) and Outside Work for Pay are not included in IBS. Administrative or clerical may be allowable when all the following criteria are met:
- Administrative or clerical services are integral to a project or activity;
- Individuals involved can be specifically identified with the project or activity;
- Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency;
- Administrative/clerical salaries on awards received prior to Dec. 26, 2014, will need to be justified, but will not require agency approval until a modification is received.
- The costs are not also recovered as indirect costs.
- Lump sum payments are discouraged because many agencies expect documentation to justify rates as the rate justification is a factor in determining the reasonableness of a cost.
- Faculty overload is generally unallowable because intra-institution consulting is assumed to be a part of faculty duties. Prior agency approval is necessary and may be granted when Faculty overload is paid across departmental lines and is in addition to regular responsibilities.
- Salary/payroll costs should be supported by completed time sheets (students/hourly pay) or Effort Report as appropriate.
- 2 CFR 200.430 (General Provisions: Compensation - Personal Services)
- 2 CFR 200.413 (Direct and Indirect (F&A) Costs: Direct Costs)
A scholarship or fellowship is typically paid as a stipend to the individual or as tuition payments and are made to encourage course/degree completion.
Cost Allowable Unallowable Agency approved scholarships/fellowships pauid on a sponsored program whose purpose is to provide training X Scholarships/fellowships used as a mechanism to pay for services X
- Due to the nature of this type of expense, it is rarely allowed on research projects as the payments are not made in exchange for services, i.e. as an employee.
- Employee benefit packages may include a component for tuition or course reimbursement and are allowable as a fringe benefit.
A sponsorship is a commitment to financially support an external entity for a specific activity.
Cost Allowable Unallowable Sponsorships with the purpose of providing funds to a project related event or activity X Sponsorships viewed as donations X
Sponsorships that provide funds to a project related event or activity are usually listed in the approved budget and may be justified by WSU participation in the event. A statement demonstrating the reasonableness of the cost should be included.
Cost Allowable Unallowable Project supplies used for the performance of the award X Computing devices that are essential and allocable to the project X Office supplies X
- When not charged solely to the project, appropriate allocation documentation should be maintained and may be reviewed.
- When project supplies are purchased near the end of a project, please refer to the Needed, Received and Used section of this policy.
- Office supplies can support numerous activities and are difficult to track for use to a specific project, and are therefore normally treated as an indirect cost, i.e. paid by General Fund accounts.
- Examples of supplies that are typically considered office supplies are toner, paper, pens, office furniture, business cards, printers, etc.
- 2 CFR 200.453 (General Provisions: Materials and Supplies Costs, Including Costs of Computing Devices)
- 2 CFR 200.413 (Direct and Indirect (F&A) Costs: Direct Costs)
Cost Allowable Unallowable Long distance charges specifically identified to a project (i.e. who was called and how those called are affiliated with the project) X Cell phone minutes, phone cards, or hardware needed for an international project X Telephone charges, such as local and cell phone costs, not easily identifiable to the project X Smart phones and related data plans X
- Local and cell phone costs can support numerous activities and are difficult to track for use to a specific project, and are therefore normally treated as an indirect cost, i.e. paid by General Fund accounts.
- 2 CFR 200, Appendix III
- 2 CFR 200.471 (General Provisions: Telecommunication Costs and Video Surveillance Costs)
- APPM Wireless Communication Devices, Services and Business Call Reimbursement 184.108.40.206
Cost Allowable Unallowable Travel costs such as transportation, lodging, and subsistence and related items incurred when necessary to support project activities X Travel advance fee when necessary for documented project related travel or under special circumstances X International transaction fee with receipt or bank/credit card statement X Change fee for airfare with documented project related business purpose or under special circumstances X Short term travel visa costs with documented business necessity X Business/First class airfare or costs in excess of the least expensive commercial travel X Dependent travel costs X Extraordinary temporary dependent care costs X
- Project related business purpose for the travel must be documented. Expenses are allowed when they are in accordance with WSU's travel policies: WSU Travel and Business Hosting Expense Policies and Procedures .
- Air travel must be compliant with the Fly America Act, if federally funded.
- Dependent costs may be allowable for travel with a duration of six months or more and with agency prior approval.
- Re-Budgeting of Grant Funds
Requests for re-budgeting of grant funds must include the following information:
- Amount to be re-budgeted
- Budget line from which money will be moved*
- Budget line to which re-budgeted monies will be placed*
- Justification for re-budgeting of funds
*Note: Keep in mind that re-budgeting can affect indirect costs based upon what budget lines are adjusted.
The requests,completed using the SPA Rebudgeting Request form, must be forwarded to the cognizant Grant and Contact Officer for processing.
- Effort reporting
Effort reporting is the mechanism used to confirm salaries and wages charged to each sponsored agreement are reasonable in relation to the actual work performed. As a recipient of sponsored funds for research, Wayne State University must assure Federal and other sponsors that the assignment of time and associated salary and fringe benefit costs to the projects they sponsor is fair, consistent and timely. Financial penalties, expenditure disallowances and even harm to the University's reputation could result from an indadequate effort reporting system or from failure to comply with effort reporting policies and requirements.
Learn more about effort reporting procedures and guidelines at Wayne State University.
The following training materials may be useful in understanding effort reporting procedures at WSU:
- Instructions for Certifying Your Own Effort (PDF)
- Instructions for Certifying Your Employees' Effort (PDF)
- Effort Reporting Guidelines (PDF)
- Effort Reporting Administrative/Pre-Review Training Handout (PDF)
- Effort Reporting Frequently Asked Questions (PDF)
- No-cost extension procedures
No-cost extensions of non-federal awards will almost always require approval from the sponsor. If guidelines for extending the budget period are not included in the terms and conditions of the award, SPA will contact the sponsor on behalf of the principal investigator (see Procedures for Obtaining a No-cost Extension below).
Federal regulations provide a set of criteria for approving a one-time extension of the expiration date of a federal award for up to twelve months. These criteria are to be used by funding agencies when they retain the authority to issue no-cost extensions or by SPA when the authority is transferred to the University (under Federal Demonstration Partnership). The extension may be issued unless one or more of the following conditions/restrictions apply:
- The terms and conditions of the award prohibit the extension.
- The extension requires additional federal funds.
- The extension involves any change in the approved objectives or scope of the project.
Agency approval for extensions longer than twelve months must be requested. If the University approves a request for an extension of less than twelve months and the principal investigator subsequently wishes to lengthen that time period to a total of twelve months or longer, agency approval must be obtained.
Procedures for obtaining a no-cost extension
SPA No-Cost Extension Request Form
The principal investigator must prepare the SPA No-Cost Extension Request Form describing the need for an additional period of time to complete the project objectives. The request must address programmatic issues and may describe justifiable delays, such as the loss of a skilled technician. The fact that there may be money remaining in the project's account is not sufficient reason for an extension. If the sponsor approval must be sought, the letter should be addressed to the sponsor grants officer but sent first to Sponsored Program Administration for an authorizing signature. If the University has been given the authority to approve the no-cost extension, the request should be addressed to the principal investigator's post-award officer in SPA.
The Timing of the Request
If sponsor approval must be sought, and if the sponsor is a federal agency, requests to extend a project period must be received by the SPA at least 30 days before the expiration date of the grant, unless otherwise specified. The principal investigator will need to send the request to SPA for review and authorization before any contact with the sponsor is made (if necessary). If the sponsor is a non-federal agency, the award document should be consulted for requirements regarding the timing of the request.
- Changing scope or research objectives procedures
A grantee organization is required to seek approval from the sponsoring agency when the scope or research objectives of the project change. Actions likely to be considered a change in scope or objectives include, but are not limited to, the following:
- Change in the specific aims approved at the time of award.
- Substitution of one animal model for another.
- Any change from the approved use of animals or human subjects.
- Shifting the emphasis of the research from one disease area to another.
- Applying a new technology, i.e., changing assays from those approved to use of a different type of assay.
- Transferring the performance of substantive programmatic work to a third party by contract or any other means.
- Change in key personnel whose expertise is critical to the approved project.
- Significant re-budgeting whether or not it requires approval under rules governing budget changes. Significant re-budgeting occurs when the cumulative amount of transfers among direct cost categories for the current budget period exceeds 25 percent of the total amount awarded, or $250,000, whichever is less.
- Incurrence of patient care costs not previously approved and/or when a grantee desires to re-budget funds out of the patient care category.
Note: This list is not all-inclusive. In the event of uncertainty as to whether a particular change is significant enough to require your sponsoring agency's prior approval, questions should be referred to your grant and contract officer.
- Change of PI or Institution Procedures and Relinquishing Statement Instructions
Once a Principal Investigator (PI) has decided to leave the institution, a decision must be made as to whether or not Wayne State wishes to retain the project. If the project is to remain here, then someone else must be identified as the PI on the project. Different agencies have different requirements as to the notification and approval process to accomplish this. The appropriate Grant & Contract Officer should be notified to coordinate the change.
If, however, the PI is transferring to another institution and they wish to take the project with them, they must first receive both agency and departmental approval to transfer a sponsored award with them. Once that approval has been obtained, the following steps must take place to relinquish the award:
- Based on sponsoring agency policies and procedures, a Relinquishing Statement must be completed by the PI. The statement will indicate the expected unobligated balance at the time of termination, including a breakdown between direct and indirect costs. It must also include a list of any equipment transferring with the award. The amount to be relinquished cannot be greater than the current year funding. The PI should work with the appropriate Grant & Contract Officer to prepare the relinquishing statement. The Grant & Contract Officer will obtain the required signature(s) and forward the documentation to the sponsoring agency. Typically, the relinquishing statement will require the signature of both LaShonda Cooley, Interim Sr. Director of Sponsored Program Administration and Marlene Erno, Sr. Director of Sponsored Program Administration - Finance.
- An Invention Statement must be completed by the PI. This discloses any inventions that were developed in direct correlation to the sponsored project, and must be completed even if there were no inventions. The Director of Technology Transfer will sign on behalf of WSU.
- A Property Report must be completed pertaining to any equipment that was purchased using funds awarded by the sponsoring agency. A designee in the Property Office will sign on WSU's behalf (APPM #6.2). Per prior approval from the Chairman and the Dean of the school/college/division, the Asset Activity Transmittal Form 195A must be submitted to the Property Office if any transfer of equipment to the new institution will occur.
- Notify the Technology Transfer Office that the PI is leaving. They will ensure that any inventions that the PI has been involved with are handled appropriately relative to the move.
NOTE: Per University Policy #86.2, when the PI leaves WSU, the balance of his/her share of indirect cost funds will revert to the department.
- Resources/Jobs Aids