Post-Award Services provides support to Principal Investigators, deans, department chairs, administrators, and other campus officials in the administration of grants, contracts, and agreements. Located in the Office of Sponsored Programs (OSP), Post-Award Specialists are assigned to each UWM Division/School/College or department to serve as the primary point of contact and to help facilitate the overall post-award process while balancing the need for institutional and sponsor regulatory compliance.
Financial and Project Management
Award management is a shared responsibility between the Office of Sponsored Programs, the Principal Investigator (PI), and the PI’s Division/School/College or unit. The process shares responsibility for award management and ensures that, as a grant recipient, UWM is a responsible steward of the sponsor’s resources.
Award Terms and Conditions Determine Costs if Costs are Allowable
The grant agreement or contract usually contains the terms and conditions for receiving reimbursement. During the award acceptance process, you will receive a copy of the agreement. Please contact the Post-Award Specialist assigned to your Division/School/College with any questions regarding financial management of the award.
For most federal and non-federal awards, your Post-Award Specialist will initiate electronic drawdowns for funds or invoice to reimburse the University for expenses posted to your project on a monthly or quarterly basis (as determined by the sponsor). In most cases, invoices are submitted with expenses by budget category. The account codes used when expenses are posted to the project will dictate which budget category an expense will appear. Please be certain to use the proper account codes. Certain sponsors also require a detailed listing of expenses accompany each invoice (or if there is a question).
It may be essential that you obtain permission from the sponsor to deviate from the approved budget. Without sponsor prior approval, the sponsor may not be obligated to reimburse expenses that are not allowed. In the event of an audit or review of expenses by a sponsor, the division/school/college may be required to return funds to the sponsor if expenses are determined as unallowable. Your Post-Award Specialist will be contact with the PI, the division/school/college, and department if there are any audit or collection issues.
Fiscal Policies that Determine if Costs are Allowable
In addition to specific terms and conditions for fiscal management contained in an award document, most sponsors require that costs adhere to the guidelines provided by the Federal Office of Management and Budget (OMB). Previous OMB circulars (A-21, A-110, and A-133) have been replaced by the Uniform Guidance, 2 CFR 200.
Allowable costs MUST:
- Be necessary and reasonable: Costs must be necessary to accomplish the scope of work and the cost applied must be essential to achieve a certain result or results. The goods or services acquired or applied to the project reflect action that a “prudent person” would take, acting in good justment and the cost incurred is considered fair. Be certain that purchases near the end of a project period, especially those for supplies and equipment, are necessary to accomplish the scope of work for that project. The last expenses charged to a project are most likely to be reviewed by sponsors.
- Conform to the limitation specified in the specific award: It is critical for PIs and division/school/college administrators to review the award documents and other sponsor policies referenced in the award to fully understand which costs are allowed and which are not.
- Be consistent with University policies and procedures: Uniform Guidance requires that all project costs are treated consistently with policies and procedures applied to federal and non-federal projects. Pay close attention to procurement and travel policies. Links to relevant University policies follow below. Please contact your Unit Business Representative (UBR) with any questions regarding University policies and processes. For unique costs to your specific project, please verify the cost is allowable under University policy, the award terms and conditions, and under the Uniform Guidance (2 CFR 200).
- Not be included in the University’s indirect cost calculations: Any costs considered “overhead” included in UWM’s Facilities and Administrative (F&A) Rate may not be charged directly to an award. Common examples include telephone charges, general office supplies, or administrative support staff.
- May not be used as cost-share another project: Cost-share is not allowed to come from another award. Departments and PIs are responsible for ensuring cost-share commitments are met from University of third-party funds.
Relevant UWM/UW System policies governing financial transactions:
- UW System Administrative Policy 306: Accounting and Budget Control
- UW System Administrative Policy 308: Budget Transfers
- Purchasing Guidelines (ASM 3 Series)
- General Travel Policy (UW TravelWise Portal)
Costs Not Allowed
The Uniform Guidance does list a few items of cost that are not allowed on federal projects. Detailed requirements of selected items of cost are included in Subpart E of the Uniform Guidance. The following are common items that are NOT allowed:
- Advertising, with detailed exceptions available in the regulations (2 CFR 200.421)
- Alcohol (2 CFR 200.423)
- Alumni Activities (2 CFR 200.424)
- Commencement Costs (2 CFR 200.429)
- Entertainment (2 CFR 200.438)
- Fundraising (2 CFR 200.442)
Costs not allowed will need to be transferred off the award. In some cases, a refund will need to be provided to the sponsor. Ultimately, it is the responsibility of the PI to monitor the expenses posted to projects and ensure costs are allowable. Your Post-Award Specialist is available to answer any cost-related questions.
Consultants and Professional Services
A consultant is an individual or entity providing professional advice or services for a fee, but normally is not an employee of the lead institution. Consultant charges must align with rates used from all sources of funding—both federal and non-federal. UW System employees may NOT be paid as consultants on any sponsored project.
Consultants and professional services will be in the “other” budget category and will usually be included in your budget justification to the sponsor.
Consultants and professional services must be procured through the UWM Purchasing Department. Prior to issuing a purchase order, the PI and/or their division/school/college/department is responsible for ensuring the vendor is not on the Federal Debarred list by checking the System for Award Management (SAM). The PI and/or their division/school/college/department will need to request the vendor’s DUNS number and conduct a search using the number. Retain the DUNS number and the search results in your file, including proof of negative results. If the vendor does not have a DUNS number, obtaining one is easy through Dun & Bradstreet.
Cost sharing is the portion of the total project costs not paid for by the sponsor but rather is covered by UWM and/or third parties. Common examples of cost-shared contributions include personnel, time, effort, travel, and facilities.
Cost-sharing has a significant financial impact on the department providing the funds and on the University as a whole; therefore, a decision to cost-share should be weighed carefully. All cost-sharing included in a proposal must be approved in advance by a representative authorized to make cost-sharing commitments on behalf of the source (e.g., PI’s dean or department chair, Vice Provost for Research).
PIs are responsible for documenting all cost-sharing commitments. PIs should work closely with the Post-Award Specialist assigned to their Division/School/College to manage the cost-share commitment/documentation process.
The following are general statements regarding cost-share commitments:
- All cost-sharing must be provided during the performance period listed in the award documentation. Cost-sharing provided prior to or after the award period cannot be included in the official cost-sharing commitment.
- Proposals to federal agencies typically may not use federal sources of funds for cost-sharing (both mandatory and voluntary).
- All cost-sharing commitments must conform to the applicable federal principles (Uniform Guidance), and must be necessary, reasonable, and allocable to the project.
- Cost-sharing may be provided from a variety of sources, including campus funds, unrecoverable Facilities & Administrative Costs, volunteer contributions, third-party contributions (such as a for-profit entity), or other non-federal sponsored programs.
Cost overruns may occur during award administration. Although post-award administration is shared between the PI, dean, department chair, and OSP, it is ultimately the Division/School/College’s responsibility to oversee all sponsored program financial activity. To properly close accounts at the end of a project period (typically within 90 days of the project end date), the following procedure has been established to improve the fiscal management of sponsored programs at UWM and to reduce the risk of financial liability, fines, and/or disbarment:
- For any account that is overspent for three months following the project end date, funds will be transferred to a non-sponsored Division/School/College account to close the project account.
- Your Post-Award Specialist will work with the PI and his/her Division/School/College to develop a plan to cover the overages.
The Uniform Guidance defines equipment as “tangible personal property (including information technology systems) having a useful life or more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-federal entity for financial statement purposes, or $5,000.” The title to such equipment vests with UWM or with the award agency in accordance with the award documentation or the Uniform Guidance (2 CFR 200.313), not with the individual PI. Equipment must be included in UWM’s inventory in accordance with UW System policy.
Indirect costs will not be applied to equipment. Equipment account codes include 4602-4604, 4620, 4630, and 4680. If your project includes constructing equipment, it is important that items used to create the equipment are charged to these account codes. Issues related to the sale or purchase of equipment purchased with federal funds may be directed to the UWM Purchasing Department or the Post-Award Specialist assigned to your division/school/college.
Materials and Supplies
Many sponsors allow no-cost extensions in the event that a sponsored program cannot be completed in the original award period. No additional funds will be provided to UWM during this period; it is simply additional time for the PI to finalize remaining project tasks. No-cost extensions typically are available for an additional 12 months.
No-cost extensions may NOT be granted in order to simply expend funds. All no-cost extensions must be appropriately justified within the context of the original scope of work and require approval from the PI’s dean and/or department chair. All no-cost extensions requests are reviewed by the Office of Sponsored Programs prior to submission to the sponsor.
To initiate the no-cost extension request, the PI should e-mail their Post-Award Specialist with a clear justification statement of the need for an extension, summary of progress to date, and the new project end date proposed. The PI should also indicate whether the effort of key personnel on the project will remain the same or will change during the extension paid, and indicate the key personnel effort during the extension will be “sponsored paid” and/or “cost-shared.”
The timeframe for submitting no-cost extensions may vary, but generally must be submitted at least 90 days prior to the original project end date. Under no circumstances should a request for an extension be sent to the sponsor after the original project end date. PIs should carefully review their award terms and conditions regarding no-cost extensions.
Participant support costs are direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences or training projects. Participants may include recipients of training (not the provider), persons that perform no work or services for the project, students, scholars, scientists form other institutions, representatives from private companies, and teachers. Participant support is/are NOT human subject incentives, honoraria paid to a guest speaker or lecturer, or conference support costs.
Participant support may include stipends and travel expenses. In most cases, Facilities and Administrative (F&A) costs are not allowed on participant support. As a result, participant support is tracked as a separate project within an award. Any decrease in the participant support budget requires sponsor approval; see your award documents for specific details. Contact your Post-Award Specialist with specific questions regarding participant support costs.
Payments to Research Subjects
PIs are strongly encouraged to carefully weigh the impact of payments to research subjects in sponsored program activities. At UWM, payments to research subjects are governed by several policies and Wisconsin State Statutes:
- UWM Policy on Payments to Research Subjects
- UW System Administrative Policy 330: Prizes, Awards, and Gifts
- Wisconsin’s Prize Notice Rules Wisconsin Statute 100.171)
- Wisconsin’s Gaming Statute (Wisconsin Statute 945.02)
PIs must carefully weigh all available options to promote participation in a research survey, and if necessary, consult with the UWM Office of Legal Affairs and/or the UWM Human Research Protection Program (HRPP). HRPP also provides guidance to PIs on particular challenges associated with various types of incentives.
Purchasing cards (P-Cards) have a default account code, which is often supplies. If the P-card is used for something other than supplies, the department or division/school/college must re-code the purchase. The PI or department must keep all receipts for purchases made on a P-card and all other University policies must be followed. At the end of the award, a P-card associated with a project must be re-assigned to another project to prevent charges outside of the project period.
Annual (or Progress) Reports
Most multi-year projects require the PI to complete annual reports, which should describe the progress in all activities related to the project during each performance period.
- The annual reporting requirements are typically set forth in the award notification.
- PIs should carefully review the sponsor’s reporting requirements at award set-up and consult with the Pre-Award Specialist assigned to your Division/School/College for further clarification.
All projects typically require a final report. All sponsors have different requirements regarding the content and format of the final reports; thus, PIs should carefully review award materials to determine the final reporting requirements.
- If annual or progress reports are required as a condition of the award, the final report typically covers only the period between the last annual report to the end of the project.
- If no progress or annual reports are required, the final report will cover the entire project period.
- Final reports may include both a programmatic/research outo
Final reports may include both a programmatic/research outcome(s) summary and financial data. PIs should consult with the Post-Award Specialist assigned to their Division/School/College in advance of the report deadline to discuss what, if any, financial data is needed for the report.
Most sponsors request financial reports during the award period. Financial reporting requirements may differ from sponsor to sponsor. PIs should consult with the Post-Award Specialist assigned to their Division/School/College for assistance with developing and submitting financial reports.
A subaward allows a PI to support a project collaborator at another institution. Typically, a Pre-Award Specialist works closely with the PI to obtain the appropriate documentation for a subrecipient during the proposal development phase. At the time of award, OSP staff will contact the PI to confirm that a subrecipient will remain involved in the project.
OSP generates the subaward (and related documentation, if required) and provides a draft for the PI to review. Once the subaward is fully executed, the PI receives a final copy along with a Subcontract/Subaward Encumbrance Request. The request must be reviewed and approved by the PI and his/her Unit Business Representative.
Many sponsored programs include funds for travel for project personnel. Here is an overview of travel issues that are common on sponsored programs; go to UW TravelWise portal for a complete list of all current travel policies and procedures.
Air travel is typically limited to the lowest available coach fare. Effective 5 January 2015, all air travel must be booked via the UW TravelWise portal using the Concur system or it will not be reimbursed. Concur uses an automated “lowest logical airfare” policy (which is a $150 tolerance threshold above the lowest rate) that allows users some flexibility in determining airlines, departure dates and times, and routes. For more information on reimbursable and non-reimbursable expenses, as well as other policy considerations, please review UW System Administrative Policy 410: Purchase & Payment of Business Air Travel for more information.
Air Travel Using Federal Funds
If you are purchasing airfare with federal funds, the Fly America Act restricts your choice of airlines. Generally, researchers must use an airline owned by an American company (i.e., “flag carrier”), regardless of cost or convenience.
Foreign carriers may be used for flights if a U.S. carrier “code-shares” with a foreign airline. A “code-share” occurs when two or more airlines “code” the same flight as if it was their own. For example, Delta and Air France code-share a flight to Paris, France. If the researcher’s boarding pass or e-ticket identifies the flight as a Delta flight, even if “Air France” is shown on the airplane, the researcher has met the requirements of the Fly America Act. However, if the researcher’s boarding pass or e-ticket indicates an Air France flight, the traveler is not in compliance with the Fly America Act and the trip cannot be reimbursed with the federal grant funds.
The U.S. government has entered into several air transport agreements that allow researchers using federal funds to use certain airlines in the European Union, Australia, Switzerland, and Japan. These agreements allow researchers to arrange air travel on foreign carriers in certain circumstances. Researchers who will travel to, from, or within these areas/countries, should contact the UWM Travel Office to discuss travel within these regions. Please be certain to indicate that the travel is associated with a federal grant or contract.
Exceptions to the Fly America Act
Travelers are not required to use U.S. flag carriers in these circumstances:
- When there is no non-stop or direct service offered by a U.S. carrier.
- When travel outside the U.S. increases the number of plane changes to a destination by more than two.
- When the passenger’s total travel time is extended by at least six hours.
- When the connective time at an overseas interchange point is four hours or more.
Appropriate Modes of Transportation
The approving authority has the responsibility to determine the most appropriate and cost effective means of transportation consistent with the authorized business purpose of the trip, and to consider all associated costs (e.g. employee work time, overnight lodging, meals, mileage).
Researchers with disabilities or who require reasonable accommodations should contact the UWM Travel Office to discuss their options. An accommodation request may be needed prior to departure.
The cost of attending conferences, workshops, symposiums, or other dissemination venues are eligible for reimbursement. Researchers should keep the receipts or other materials that document the registration fee associated with attendance.
The University’s maximum lodging rates are based upon the General Service Administration, Departments of State and Defense rates for the location and dates of stay. The maximum rate is for a single/standard sleeping room per person or single occupancy.
For lodging associated with an externally-designated conference, the maximum lodging rate does not apply if the attendee stays at the venue location. For lodging associated with a UW System-designated conference, the cost may not exceed the maximum rate for the location.
Additional information regarding maximum lodging rates is available in UW System Administrative Policy 415: Purchase & Payment of Lodging. Additionally, faculty and staff may pre-plan their expenses using the new Lodging, Meals, and Incidental Expenses Calculator.
When the University traveler is expected to incur costs for meals and incidentals for overnight business travel, the University will reimburse meal and incidental expenses (M&IE) under a per diem allowance. The maximum M&IE per diem allowance will be at the rate established by the General Service Administration, Departments of State and Defense for the location of each full day’s (24 hours) travel. The M&IE per diem allowance will only be paid when the traveler is expected to incur costs for meals and incidentals; business travel requires an overnight stay outside the traveler’s headquarters and when the travel is supported by a University business purpose.
For Continental U.S. locations, the incidental portion of the M&IE per diem allowance is $5.00. For Non-Continental U.S. and foreign locations, the incidental portion of the M&IE per diem varies by the location.
Travel that does not include an overnight stay will be limited to a tax reportable day trip meal allowance of $15 per day when the approving authority expects the traveler to incur meal expenses. No day trip meal allowance will be paid when the traveler receives a provided meal, regardless of amount.
For assistance with calculating maximum M&IE, please use the new Lodging, Meals, and Incidental Expenses Calculator. Additional information related to maximum M&IE rates is available in UW System Administrative Policy 420: Travel & Expense – Meal and Incidental Expense (M&IE) Per Diem Allowance Reimbursements.
Other expenses are permitted if they are necessary, reasonable, and allocable for the conduct of University business, such as photocopying, Internet, fax, or telephone services or charges. Keep receipts to verify charges; additional justification may be necessary for some expenses.
Personal vehicles may be used for activities on your sponsored project. Reimbursement is provided at the University’s standard mileage rate for personal vehicles (e.g., cars, trucks, vans). Business mileage will be reimbursed at the IRS authorized mileage rate in effect on the date of travel using the most direct route. For personal vehicles, this rate is $0.575/mile; for motorcycles it is $0.545/mile.
All individuals requesting mileage reimbursement must have an approved Driver Authorization Form on file with the UWM Risk Management Office prior to travel (typically a one-time requirement). Reimbursement is typically limited to standard map mileage/calculations; a justification is required for mileage reimbursement requests that exceed the available map mileage/calculations.
Additional information related to mileage reimburse is available in UW System Administrative Policy 425: Use of Personal Vehicles, Rental Cars and Fleet for Business Transportation.
Rental vehicles may be used for activities on your sponsored project. UW System has contracts with Enterprise and National Car Rental, which must be used if vehicles are available. If traveling in Wisconsin, the State has agreements with Hertz, Enterprise, and National Car. All contracted rental car providers include the cost of insurance in the rates for UW System. If traveling domestically, rental car reservations must be made via Concur.
Rentals are limited to compact/standard/intermediate vehicle classes. Claims for reimbursement beyond standard/intermediate vehicle classes (i.e. trucks, vans, etc.) for business reasons such as transporting extra passengers, carrying cargo or bulky equipment, etc., must be explained on the expense report.
Additional information related to mileage reimbursement is available in UW System Administrative Policy 425: Travel and Expense – Use of Personal Vehicles, Rental Cars, and Fleet for Business Transportation.
Taxi, Limousine, and Shuttle Services
Necessary, reasonable, and allocable charges for ground transportation are reimbursable. Whenever possible, use shuttle services offered by lodging facilities and/or conference sites, which are typically free. Receipts are required for all fares that exceed $25.
Additional information related to taxi, limousine, and shuttle services is available in UW System Administrative Policy 430: Travel & Expense – Purchase & Payment Miscellaneous Travel Expenses.
UW System has developed a Travel Calculator to assist Principal Investigators with developing budget estimates for travel. Use of the Travel Calculator is highly encouraged for those Principal Investigators developing travel estimates for inclusion in federal grant and contract submissions. Under the Uniform Guidance, proposals must now include a detailed breakdown of travel costs (airfare, lodging, meals, registration/conference registration fees, taxi/shuttle services, rental cars, etc.). The Travel Calculator will provide lodging and meal estimates based on location and dates of travel.
Travel by Students, Participants, and Other Personnel
Travel on sponsored programs is typically permitted for students, participants, and other personnel, so long as the travel is necessary, reasonable, and allocable. Travel is usually incorporated into the budget at the proposal stage and approved during the initial award negotiation phase.
The allocation of travel across cost categories may vary across grant programs. For example:
- Travel for undergraduate, graduate, or doctoral students on a research grant will likely be charged to the “Travel” budget category; however,
- Travel for undergraduate, graduate, or doctoral students on a training or education grant will likely be charged to the “Participant Support” budget category.
In these instances, charges allocated incorrectly may have an impact on other cost categories (e.g., Facilities & Administrative Costs). Consult with the Post-Award Specialist assigned to your Division/School/College to discuss modifications to travel expenses for students, participants, or other personnel.
The Wisconsin Data Mart (WISDM) is a Web-based financial data reporting that provides detailed information regarding grant award budgets and expenditures.
Account balances available in WISDM are likely the best estimate of available funds; however, due to timing and other limiting factors, it is typically not the actual account balance. Certain expenditures are processed monthly: for example, charges for fringe benefits and indirect costs typically occur in the first week of the month for the preceding month. Therefore, an account balance on the first of any month will not include last month’s fringe benefit and indirect cost charges. PIs are strongly encouraged to connect periodically with the Post-Award Specialist assigned to their Division/School/College to obtain a more detailed and accurate account balance projection.
Cost Principles for Award Management
There are many regulations that govern federal sponsored programs at U.S. colleges and universities. Below is a list of the major requirements; federal and non-federal sponsors may have additional regulatory compliance requirements for award recipients.
U.S. Office of Management and Budget (OMB) Guidance
OMB is responsible for assisting the President of the United States with the preparation of the federal budget and supervising the administration of Executive Branch agencies. OMB also oversees and coordinates the Administration’s procurement, financial management, information, and regulatory policies.
On 26 December 2013, OMB released its final guidance on the changes to OMB Circulars A-21, A-110, and A-133. New federal awards issued after26 December 2014 will be governed by the Uniform Guidance. Continuations may or may not utilize the Uniform Guidance; seek guidance from your Post-Award Specialist on which terms and conditions govern your award.
Cost Principles for Educational Institutions (Revised 8 August 2000 and Amended 10 May 2004). This Circular has been relocated to 2 CFR 220. Most continuation awards issued under OMB A-21 have transitioned to the Uniform Guidance (see above).
Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations (Revised 27 June 2003 and 26 June 2007). This Circular has been relocated to 2 CFR 215. Most continuation awards issued under OMB A-110 have transitioned to the Uniform Guidance (see above).
Audits of States, Local Governments, and Non-Profit Organizations (Revised 27 June 2003 and 26 June 2007). Most continuation awards issued under OMB A-133 have transitioned to the Uniform Guidance (see above).
Provides guidance on managing and monitoring the award and administration of NSF grants and cooperative agreements. Information includes an overview of the NSF award process, award administration, financial management and payment, grantee standards, allowability of costs, and other award-related administrative topics.
Serves as the general terms and conditions for most NIH awards on terms and conditions applicable to: the type of funding mechanism or grantee type; multiple project director/principal investigator awards; construction, modernization, or renovation grants; research training grants and fellowships; career development awards; modular applications/budgets and subsequent awards; and conference grants.
Guide for administering funds from the U.S. Department of Education.
Award close-out begins once the appropriate final reporting requirements have been satisfied by the PI(s) and any subrecipients/collaborators/partners. Reporting requirements typically include a final technical and financial report; the sponsor may require additional documents such as patent/intellectual property disclosures, mentoring/education plans for post-doctoral positions, and equipment inventory. Once all requirements have been met, the Post-Award Specialist will initiate the close out process.
Financial Data Review
PIs are strongly encouraged to consider the following questions before, during, and after the award close-out process:
- Are all accounts tied to the project at a $0 balance? If not, what is the plan to expend or transfer funds?
- Have all project personnel satisfied their effort for the project?
- Have all subrecipients submitted their final invoices for reimbursement? Subrecipients have 45 days from the end of the award to submit their final invoice for payment.
- Has all cost-sharing been satisfied for the project (including subrecipient cost-sharing)?
- Has the data management plan and/or long-term data storage requirements been satisfied?
- Have the final technical and financial reports been submitted to the sponsor?
- Have all other reports/documentation requested by the sponsor been submitted?
- Has the UWM Institutional Review Board or Institutional Animal Care and Use Committee been notified that the project has ended? Have the final reports been submitted to the appropriate institutional research committee(s)?
- Have all biological safety and/or radiation safety compliance requirements been satisfied?
- Have all purchasing and/or travel cards associated with the award been destroyed?
Sponsored Programs Glossary/Acronyms
Research administration uses many acronyms and terms. This glossary and acronyms list provides an overview for many common terms.