Post-Award Reminders & FAQs
RMG’s Research Financial Compliance Group offers some Reminders & FAQs on a variety of post-award research administration topics to aid in the management of sponsored projects in compliance with sponsor and university guidelines.
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Appointments must meet the minimum effort requirements of the K-Award. Effort charged to the grant must clearly document and demonstrate fulfillment of the sponsor’s required effort throughout each project period (Including No-Cost Extension periods).
Reference: NIH GPS Section 12.3.6 Level of Effort
K award recipient must be able to devote the necessary level of effort to the project. For the K01, K08, and K23 awards, the required percentage of effort per budget period generally is 75 percent. Some institutes have a different effort requirement. It is best to check the RFA.
In addition, career award recipients that have a dual appointment with the VA must have at least 3/8th appointment to meet the minimum effort requirement.
TRACKING SALARY LIMITATION & SALARY CAP
K Awards often have salary limits depending on the participating Institutes and programs. The salary limit (excluding fringe benefit) is not the same as the legislative mandated salary cap.
Salary over the K grant salary limitation, but under the NIH salary cap must be accounted for in a cost sharing PTA. Salary over the salary cap should be accounted for by using expenditure type 51190 on the PeopleSoft Job Earnings Distribution Panels which allocate salary costs.
Reference: DoResearch: 15.5 Salary Cap Administration
REBUDGETING OF FUNDS
Funds may be rebudgeted between categories without prior approval. You may rebudget funds from salary into other categories, but this would create or increase the cost sharing commitment. You may rebudget funds from another category to cover a higher salary and reduce cost sharing commitment.
Reference: NIH 12.9 Rebudgeting of Funds
ALLOWABLE USE OF NON-SALARY FUNDS
Career Development Awards (CDAs) may include a fixed amount for research development support costs. This amount may vary by IC and is commonly used for supplies, equipment, technical personnel, travel to research meetings or training, tuition/fees for courses and computational services.
Mentored CDA programs provide support with a goal of leading to research independence for an individual. Since research independence is achieved through applying for other research support, consistent with these objectives, it is allowable for effort devoted to proposal preparation costs for subsequent research support to be charged to a mentored CDA award. This can be considered part of the awarded effort commitment of the mentored CDA or an increase to that commitment with the allowable salary provided as applicable.
K awards generally will not provide salary support for mentors or any administrative personnel.
A reduction of effort, from the minimum required effort, requires prior approval and in most cases reductions are allowed only for personal, health, and/or family matters, not to perform other research or clinical activities.
Effort during the no cost extension period must continue to meet the minimum effort requirement of the program.
NIH allows K-award recipients to reduce their level of effort required for the career award and replace that effort with an NIH research grant or subproject provided they remain in a mentored situation. This policy will permit those candidates who are ready to apply for and receive NIH research support to continue to benefit from the period of protected time offered by the career development award.
Effort on non-NIH awards is allowable as long as NIH effort commitment is met on the CDA.
Effort on other NIH award can be subsumed under the K award when there is scientific overlap. Salary is not charged to the other NIH award.
References: NIH GPS Section 220.127.116.11 Concurrent Support
SALARY SUPPLEMENTATION & COMPENSATION
Notice Number: NOT-OD-17-094
Clarification and Update: Salary Supplementation and Compensation on Research Career Development ("K") Awards
Salary Supplementation and Compensation during the Entire Career ("K") award
The recipient institution may supplement the NIH or AHRQ salary contribution on "K" awards up to a level that is consistent with the institution's salary scale. For effort directly committed to the "K" award, salary supplementation is allowable, but must be from non-Federal sources (including institutional sources). Non-Federal or institutional supplementation of salary must not require extra duties or responsibilities that would interfere with the goals of the "K" award.
For effort not directly committed to the "K" award, "K" award recipients may devote effort, with compensation, on Federal or non-Federal sources as the Program Director/Principal Investigator (PD/PI) or in another role (e.g., co-Investigator), as long the specific aims of the other supporting grant(s) differ from those of the "K" award.
A request must be submitted to NIH to confirm there is no overlap.
Note: italicized items below are from the NIH Research Training and Career Development FAQ
Generally, pre-award costs are not allowed.
Do Training Grants have pre-award cost authority?
Stipends and tuition and fees may not be charged to the grant before a trainee is officially appointed and the appropriate paperwork submitted to NIH. There are rare occasions when costs associated with training related expenses and/or trainee travel may be allowable as pre-award costs. Consult with the relevant Grants Management Officer of the Institute/Center when considering pre-award costs.
REBUDGETING OF FUNDS
Rebudgeting into or within the stipends and tuition/fees is allowable without prior approval of the NIH awarding IC. However, stipends and tuition cannot be rebudgeted into travel and trainee related expenses. See NIGMS's Rebudgeting Matrix.
TRE – Training Related Expenses such as staff salaries, consultant costs, equipment, research supplies, staff travel, trainee health insurance (self-only or family as applicable), and other expenses directly related to the training program.
Can I use the money awarded for stipend and tuition and fees from a fellowship or training grant to pay for health insurance if the TRE funds are not enough for health insurance?
No. Funds awarded in the stipend or tuition and fee categories may not be used for other purposes except under unusual circumstances, and only with the prior approval of the NIH awarding office.
PERIOD OF SUPPORT
Trainees under institutional research training grants generally are appointed for fulltime 12-month continuous periods. Appointments less than 9 months requires prior approval from NIH.
All trainees are required to pursue their research training on a full-time basis. Full-time is generally defined as devoting at least 40 hours per week to the program
Reference: NIH GPS Section 18.104.22.168 Trainees
A trainee may be appointed any time during the budget period for an appointment period of 9 to 12 months.
The stipend may be prorated in the grant award during the period of any approved part-time training. Part-time training also may affect the rate of accrual or repayment of the service obligation for postdoctoral trainees. In no case will it be permissible for the trainee to be engaged in Kirschstein-NRSA-supported research for less than 50 percent effort.
Individuals who must reduce their commitment to less than 50 percent effort must take a leave-of-absence from a Kirschstein-NRSA training grant.
Written prior approval is required if remaining months of the slot can be used for another trainee.
Reference: NIH GPS Section 11.3.6 Period of Support
At the time of the initial appointment and subsequent reappointment of trainees, the Training PD/PI must submit a Statement of Appointment for each trainee through Xtrain. In addition, a signed Payback Agreement must be submitted for each postdoctoral trainee who is in his/her first 12 months of Kirschstein-NRSA postdoctoral support. The Payback Agreement must be mailed to the IC and a copy must be retained by the department.
Stipends or other costs may not be charge to a grant until a trainee has been officially appointed and the appropriate paperwork have been approved by NIH.
Reference: NIH GPS Section 22.214.171.124 Statement of Appointment (Form PHS 2271)
When it is time to terminate a trainee you should review their stipend payments against the appointment forms and address any issues before you initiate the process on xTrain.
Reference: NIH GPS Section 126.96.36.199 Termination Notice (Form PHS 416-7)
Stipends can be supplemented from non-Federal funds provided the supplementation is without any additional obligation for the trainee.
Trainees may seek part-time employment and may spend on average, an additional 25% of their time (e.g., 10 hours per week maximum). Compensation may not be paid from a research grant that supports the same research that is part of the trainee’s planned training experience. Effort devoted to a grant must be paid as salary, not stipend. This is not considered stipend supplementation.
Reference: NIH GPS Section 11.3.10 Stipend Supplementation, Compensation, and Other Income
A Termination Notice for each trainee must be submitted within 30 days of the end of the total period of support through xTrain. The form must be routed and verified by OSR Accounting.
Reference: NIH GPS Section 188.8.131.52 Termination Notice (Form PHS 416-7)
ALLOWABLE AND UNALLOWABLE COSTS
Stipends must be paid in accordance with established stipend levels. No departure from the standard stipend provided by NIH under the grant may be negotiated by the recipient organization with the trainee. NIH stipend amounts may be adjusted only at the time of appointment or reappointment. For appointments of less than 12 months, the stipend will be prorated. Research Administrators must work closely with the OSR post-award accountant to resolve any discrepancy between stipend calculated on the Termination Notice and stipend amount paid by Stanford.
Tuition and fees are awarded as a lump sum that can be allocated (without the prior approval of the NIH awarding IC) based on recipient needs.
The NIH provides a lump sum for Training Related Expenses (TRE) that may be used, among other things, to defray health insurance costs to the extent that the same health insurance fees are charged to regular non-Federally supported students and postdoctoral fellows. Applicants may request the lump sum for TRE specified in the funding opportunity announcement.
Health Insurance. Health Insurance (self-only or family) are allowable trainee related expenses only if such charges are applied consistently to all individuals in a similar training status at the organization, without regard to their source of support. Health insurance can include coverage for costs such as vision and/or dental care if consistent with organizational policy.
Allowable costs at Stanford: health care (including the Campus Health Service Fee when required), dental and vision premiums, if elected, but not disability. Additionally, the health care must be obligated at the time of appointment.
Can the salary/benefits of the program director and/or co-director be charged to a training grant?
Training Related Expenses can be used to help defray costs such as staff salaries. However, such charges must meet the test of allocability and reasonableness. See the NIH Grants Policy Statement, Section 184.108.40.206 Training-Related Expenses.
OTHER PRIOR APPROVALS
A training grant award included stipends for two postdocs at level 1, but the actual trainees are at level 1 and level 3. What should be done?
The Grants Management Specialist identified in the Notice of Award should be consulted. Some Institute/Centers expect grantees to re-budget to accommodate this type of change; others may be able to provide additional funds.
1. Are bonuses allowable on sponsored projects?
- Faculty bonuses are NOT allowable on sponsored projects
- Faculty bonuses must be paid from non-sponsored funds
- Faculty bonus ETs 51905 and 51915 are blocked on all sponsored PTAs
- Staff bonuses may be allowable on sponsored projects
- Generally, bonuses coded as follows would be allowable for staff on federal awards and non-federal awards, provided they are not prohibited by the sponsor* (see table)
- Performance bonus should be allocated to the project that benefitted from the extra ordinary performance
|EARN CODE||EARN CODE DESCRIPTION||PRESCRIBED USAGE||ALLOWABLE ON SPONSORED PROJECTS?*|
Performance bonus award per Staff Pay Program Guide
Yes, allocate to the awards that directly benefitted
Bonus - Sign-On
Sign-on bonus per the Staff Pay Program Guide
Yes, allocate over all sponsored awards that will benefit from the staff’s work
Bonus - Retention
Retention bonus per the Staff Pay Program Guide
Yes, allocate over all sponsored awards that benefitted from the staff’s work
Bonus - Incentive
2. Are cell phone charges (including stipends) allowable on sponsored projects?
- Mobile equipment expenses are not normally chargeable to federally-funded sponsored projects or to state-funded projects subject to OMB 2 CFR 200 "Uniform Administrative Requirements, Cost Principles and Audit Requirements" Research Policy Handbook Section 15.4. The Office of Sponsored Research must approve exceptions when a proposal is submitted for any sponsored projects, both federal or non-federal.
3. Are membership dues/fees allowable on sponsored projects?
- Federally Sponsored Projects
- An individual's membership in business, technical, and professional organizations is generally not an allowable expense as a direct charge on a federally sponsored project and as such will be blocked in Oracle.
- Non-federally Sponsored Projects
- An individual's membership fees in business, technical, and professional organizations may be charged to non-federally sponsored projects (excluding sponsors who cite A-21 or Uniform Guidance) as long as the benefit can be adequately articulated in the business purpose.
- Unallowable Membership Dues/Fees
- Membership fees or dues, such as airline, social, dining and country club dues cannot be charged directly to federal or non-federal sponsored projects. Such expenses must be coded to unallowable membership fees/dues (52255)
1. What is the most appropriate way to charge salary expense? Based on the per patient costs in the internal budget?
- Salary charges to the study should tie to actual expended effort by the PI and coordinator.
2. What if the coordinator is actively working on the project but no patients have been enrolled?
- When the coordinator expends effort on recruiting, but no patients are enrolled, the effort needs to be taken into account and charged to the study. The department can review and adjust the effort on a quarterly basis to capture the recruiting effort, just the same as PI effort.
- If the actual effort expended appears to be higher than estimated in the internal budget, talk with RMG about requesting additional funding from the sponsor, or the possibility of stopping the study.
3. How do we account for the variation in effort as enrollment fluctuates?
- Effort can be averaged over the academic quarter (October to December, January to March, April to June, July to September).
4. Who is responsible for deciding how effort should be charged to the study?
- The PI quarterly certification of expenditures is an affirmation of the allocation of effort and charges to each study.
5. How are effort and salary costs for each study calculated?
- The internal budget is generated by RMG with the cooperation of the PI and coordinator, who provide estimates of hours or percent effort needed to execute a study.
6. Should we charge the percent effort indicated on the internal budget?
- The effort in the internal budget should serve as a guide to facilitate discussion with the PI about his/her level of effort devoted on a per patient basis. This is not the same as a research grant. (see question 1 above).
7. Who is responsible for tracking and providing information to properly invoice the sponsor?
- The financial analyst should work with the coordinator to track patient completions, patient milestones, invoiceable procedures/items, amounts owed, payments received (including payments from monitors), and effort expended by study staff. Based on patient completions and milestones, invoicing is done through CRISP.
8. What if the financial analyst thinks that expenses are higher than indicated on the internal budget?
- The internal budget is an estimate of costs, not actual charges. If the financial analyst observes a wide variance between the internal budget estimates and actual charges, it should be discussed with the PI and coordinator as soon as possible so rebudgeting can be attempted or additional funding can be requested.
9. What if the sponsor asks us to conduct additional tests or additional visit?
- If additional funding is needed, RMG must be involved in any sponsored project. Contact your RPM or CTRPM. For clinical trials, a contract amendment is required so a contract officer in the Office of Sponsored Research will also be involved. Finally, an IRB revision usually is required in these instances and the CT RPM will be sure that the consent matches the revised work scope and that the IRB has approved the revised protocol.
10. What do we do when the current salary does not match the salary in the internal budget due to salary increases?
- The internal budgets from RMG include estimated inflation including 3% for salaries at 9/1. The study will be charged whatever it is the current salary, but the internal budget should account for inflation, if the project begin and end dates match the internal budget.
11. Why don't the patient care costs charged to the study match the internal budget? Doesn't the internal budget indicate my negotiated patient care costs?
- The internal budget is an estimate, based on prices at the time the budget is created. RMG adds inflation 10% for laboratory, technical/hospital, and supply charges at 9/1, and 5% for pro-fees at 9/1. For both LPCH and SHC, the hospital will charge the current procedure price, with a research discount. Patient care costs are not fixed, so departments should expect annual cost increases. In addition, the research discount can vary over time. So it would be rare to see an exact match between the budgeted patient care cost and the actual charge.
12. We received a no cost extension on our study, but there was no change in the study protocol. What will that do to our budget?
- Extra care should be taken during a no-cost extension as there may be a shortage of funds, since no inflation was budgeted for the additional effort that may be required during the extended performance period.
13. How should we charge PI and study coordinator salary for start up of the study?
- Although studies vary, in general effort related to start-up would be expected to be charged to the study account within the period of performance or at the start of the study.
14. Do we invoice patient costs based on the rate in the sponsor’s payment schedule or the Stanford internal budget? What amount does the sponsor pay?
- All invoices to the sponsor for patient costs should reflect the amount negotiated and indicated in the sponsor’s payment schedule NOT the amount in the internal budget. Because of the contingency built into the budget, invoices should be based on the payment schedule, which always is included in the contract and Notice of Award (NOA). The sponsor will pay based on the payment schedule and CRFs submitted.
15. Is there an easier way to reconcile payments stemming from data reviewed between a CRO and the study coordinator?
- The financial analyst will need to work closely with the coordinator to track what has been submitted to or reviewed by the sponsor/CRO. See also question #7. The data that the sponsor reviews should reflect patient enrollment and completion, so payments should match patients’ status. Close and frequent collaboration between the coordinator and financial analyst would seem to be a critical component of tracking and reconciling payments.
16. How do we reconcile annual salary when not provided with the NOA?
- Salary charged to the study should reflect actual % effort x actual salary including any supplements for the period under review. The internal budget calculations begin with current salary, but inflation is added to estimate salary increases. Thus there will be no direct “reconciliation” between the salary amounts in the NOA or internal budget versus the salary charged to the study.
17. How is salary calculated on the internal budget?
- A typical salary calculation for Year 1 would be current salary (including supplements) /12 x # months in the current fiscal year x % effort + 3% inflation if the budget period crosses fiscal year. A 3% inflation is also added on future years. Also, see Question #5.
18. How do we address errors on an NOA?