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.
Allowability of Costs
Award Terms and Conditions Affect the Allowability of Costs
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 some federal projects, your Post-Award Specialist will initiate electronic drawdowns for funds as specified by the agency. In other cases, your Post-Award Specialist will establish a schedule for invoices, submitted in a form acceptable to the sponsor.
It is important to understand what you need to do to help your Post-Award Specialist recover project costs from the sponsor. For example, the sponsor may accept invoices only after you have completed a certain task and/or provided a stated deliverable (usually by a specified date). In this case, notify your grant accountant that a condition for payment has been met.
In another case, the sponsor may request quarterly invoices accompanied by a detailed accounting of expenditures for reimbursement. It may be essential that you obtain permission from the sponsor to deviate from the approved budget. Without sponsor approval, the sponsor may not be obligated to reimburse unauthorized expenses. Your Post-Award Specialist will keep you informed if there is a problem with the collection of payments.
Fiscal Policies Affect the Allowability of Costs
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). Following are circulars related to fiscal management of grants and contracts for the University:
- Circular A-21 establishes cost principles applicable to grants, contracts, and other agreements with educational institutions.
- Circular A-110 outlines uniform administrative requirements for grants and cooperative agreements (not contracts). Each federal agency must formally issue its implementation of A-110 (see Agency Implementation).
- Circular A-133 establishes audit requirements for institutions of higher education and other nonprofits.
- Circular A-81 (also known as the Uniform Guidance and 2 CFR 200), which was effective 26 December 2014. A-81 attempts to streamline the federal award management process by combining the principles of A-21, A-110, and A-133 into one set of regulations.
Briefly, in order to be reimbursed for costs by sponsors, the costs must be:
- Necessary: Costs must be necessary to accomplish the scope of work, i.e., the cost applied must be essential to achieve a certain result or results.
- Reasonable: The goods or services acquired or applied to the project reflect action that a “prudent person” would take, i.e., the decision is made acting in good judgment and the cost incurred is fair.
- Allocable: The cost is incurred solely to advance work on the project, i.e., the determination of the cost can be approximated through reasonable methods, and the cost is necessary and, therefore, deemed assignable to the project. Costs allocable to a particular sponsored agreement may not be shifted to other sponsored agreements for any reason.
If a cost cannot meet all of the above criteria, it is unallowable and will not be reimbursed by the sponsor. Even though an unallowable cost may initially be reimbursed, it may be disallowed in a future audit. If this happens, UWM will have to refund the unallowable amount to the sponsor. Furthermore, in many cases, UWM will have to pay a fine in addition to the original unallowable cost amount.
University policies and procedures also govern the allowability and appropriateness of expenditures. If you are unfamiliar with these policies and procedures, contact your Unit Business Representative (UBR) for guidance in maneuvering through the various processes related to various types of expenditures.
- 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)
Post-Award Specialist’s Role in Recovering Expenses
- To provide the PI with account information upon request.
- To monitor expenditures according to the guidelines of the grant or contract.
- To contact the department and/or PI regarding questionable expenditures and to coordinate corrections.
- To inform the Principal Investigator, department, school, and/or college business office if the account is overspent.
- To approve timely salary or expense transfers after verifying that the money is available and that the expense was incurred within the time frame of the project.
- To request documentation of cost-share/matching provided by the school/college when required.
- To prepare and submit invoices, interim and final financial reports to sponsor.
- To follow up with sponsor if payments are delinquent.
PI’s Role in Recovering Expenses and Project Management
- To contact the school or college dean’s business office to initiate cost-share/matching expenditures when appropriate, e.g., linking a course buyout with a particular grant so you can document that release time was provided to work on the project.
- To read and understand the reporting requirements of the grant or contract.
- To review and approve invoices from subcontractors.
- To monitor expenditures against the account in WISDM and verify account balances with the grant accountant.
- To adhere to the budget that was approved by the sponsor at the time of the award.
- To discuss any necessary changes in the budget as soon as the need becomes apparent.
- To spend the funds in the time frame outlined in the agreement. Transferring expenses to a project near the conclusion of the project raises questions for the sponsor regarding the appropriateness of the transfer.
- To prepare and transmit technical reports to the sponsor as required.
- To inform both your pre-award proposal reviewer and your grant accountant if there may be a problem developing with your sponsor.
Unallowable Cost Procedure
- Post-Award Specialists will review expenses charged against grants and contracts to ensure allowability and allocability to the project.
- If an unallowable expense is charged to a grant/contract, the Post-Award Specialist will follow-up with the PI, department chair, associate dean, and/or dean to remove the expense from the award.
- The expense will be transferred to another account (department fund, division fund, PI’s indirect cost recovery fund, etc.). Please note that depending on the nature of the expense, it (a) may not be used to satisfy any cost-share commitments and (b) may dictate the type of account in which the expense will be transferred.
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 (OMB Circular A-21 or the 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, 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 six months following the end of project activities, funds will be transferred to a non-sponsored Division/School/College account to close the project account.
- OSP will work with the PI and their division/school/college to develop a plan to cover the overages.
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 or department chair. All no-cost extensions requests are reviewed by the Office of Sponsored Programs prior to submission to the sponsor.
The time frame 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.
The “final report” due date now becomes an “interim report” due date. PIs should prepare to submit an interim report in lieu of a final report if a no-cost extension request is approved by UWM and the sponsor. A no-cost extension request does not serve as an annual report.
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) may be used on sponsored programs. P-Cards allow PIs to make low-dollar purchases in a more efficient manner; however, it does not eliminate the burden of ensuring that the items are necessary, reasonable, and allocable. The PI is responsible for documenting all appropriate expenditures connected with P-Card use.
To obtain a P-Card, PIs should connect with the UBR assigned to their Division/School/College. All cardholders are expected to adhere to the UWM Visa Purchasing Card Program Cardholder Manual.
Program Code Lookup Tool
To ensure the accuracy and consistency of sponsored program activity reporting, all expenses charged to 133 and 144 accounts must be assigned the correct program code. During the pre-award stage, each project is assigned a project type: research, public service, or instruction. Projects may only have one project type; a project with multiple research and public service components is assigned a type that aligns with the majority of activities. Program codes are also available in WISDM; the “UW Project Type” is available in each individual project screen.
All expenses must be assigned the correct program code based on the project type, even if the specific expense does not align with the overall project type. Thus, any expense to a “research” project will be coded as a 4 (research) and all expenses to a public service/outreach project will be coded as a 5 (extension and public service). The Program Code Lookup Tool allows staff processing these expenditures to quickly determine the appropriate program code.
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. 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. 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.
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.
Many 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 their Unit Business Representative before the amount of the subaward is encumbered in WISDM.
Many sponsored programs include travel funds for project personnel. Below is an overview of common travel issues on sponsored programs. See the UW System TravelWise Portal for a complete list of travel policies and procedures.
Air travel is typically limited to the lowest available coach fare. All air travel must be booked via the UW TravelWise Portal. In some instances, travelers may be able to save on airfare if they leave on certain days/times. Additional days may be claimed if the traveler can document that the modifications would save money for the University or grant award.
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 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 on 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. Please be certain to indicate that the travel is associated with a federal grant award.
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 is four hours or more at an overseas interchange point.
Appropriate Modes of Transportation
Automobile transportation is recommended on round-trips of up to 400 miles. The use of personal or rental vehicles should be carefully weighed in the decision. Commercial air travel is recommended for longer trips.
Researchers and/or project participants with disabilities or who require reasonable accommodations should contact the UWM Travel Office to discuss 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.
In-state lodging is limited to $82 per night, except in Milwaukee, Waukesha, and Racine counties, where the maximum is $90 per night. Domestic and international travel maximums are based on the date and location of the stay; additional details are provided in the UW TravelWise Portal. For lodging associated with a conference, the maximum rate does not apply if the attendee stays at the venue location.
Meal claims must be necessary, reasonable, and allocable. For any claim in excess of the maximum rates, the researcher must present a receipt and demonstrate the cost was incurred due because it was beyond their control. Maximums are based on actual expenses, not per diems. The current meal reimbursement rates are available in the UW TravelWise Portal.
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.
Taxi, Limousine, and Shuttle Services
Reasonable and necessary 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.
Travel by Students, Participants, and Other Personnel
Travel on sponsored programs typically is 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 pre-award 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.
Personal vehicles may be used for activities on a sponsored program. Reimbursement typically is permitted at the University’s standard mileage rate for personal vehicles (e.g., cars, trucks, vans). Specially-equipped vehicles for individuals with disabilities and motorcycles have an alternate rate for reimbursement.
All individuals requesting mileage reimbursement must have an approved Driver Authorization Form on file with the UWM Office of Risk Management prior to travel (typically a one-time requirement). Reimbursement typically is limited to standard map mileage/calculations; a justification is required for mileage reimbursement requests that exceed the available map mileage/calculations.
Rental vehicles may be used for activities on your sponsored project. UW System has contracts with Enterprise and National Rental, which must be used if vehicles are available. If traveling in Wisconsin, the State has agreements with Hertz, Enterprise, and National Rental, which include free collision/liability insurance on domestic rentals. Prior approval is required to use either a non-contract supplier (other than Enterprise, National, or Hertz in Wisconsin) or if you need a vehicle larger than the intermediate- or standard-class sizes.
The Wisconsin Data Mart (WISDM) is a Web-based financial data reporting tool 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.
Principal Investigators 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.
Cost Principles for Educational Institutions (Revised 8 August 2000 and Amended 10 May 2004). This Circular has been relocated to 2 CFR, Part 220.
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, Part 215.
Audits of States, Local Governments, and Non-Profit Organizations (Revised 27 June 2003 and 26 June 2007).
On 26 December 2013, OMB released its final guidance on the changes to OMB Circulars A-21, A-110, and A-133. A-81 attempts to streamline the federal award management process by focusing resources on outcomes and performance improvement. A-81 will become effective 26 December 2014.
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 committee?
- Have all biological safety and/or radiation safety compliance requirements been satisfied?
- Have all purchasing and/or travel cards associated with the award been removed from the award?
Sponsored Programs Glossary/Acronyms
Research administration uses many acronyms and terms. This glossary and acronyms list provides an overview for many common terms.