7.1 Post-Award Changes and Approvals

1. Change in the Statement of Work or project objectives;
2. Increase in the amount of funds budgeted;
3. Changes in the status of the PI, key personnel, or the addition of other subawardees working on the project;
4. Changes in the budget that does not fall within rebudgeting authority prescribed by the sponsor;
5. Change in period of performance.

As addressed in the rebudgeting section at Section 6.3, sponsors have differing administrative policies and Grants Management should be consulted when considering a revision to a sponsored program.

No-Cost Extensions
The expiration date of a grant or contract may usually be extended if additional time is needed to assure successful completion of the project. This is referred to as a no-cost extension. The project's budget period normally may be extended, when justified, for up to twelve (12) months beyond the ending date of the budget period as shown on the award notice, but this is dependent on the sponsor's policies. Extensions are generally made without additional funds.

Some federal sponsors have delegated authority to the Health Science Center to approve a one-time no-cost extension of up to twelve (12) months on grants. For these sponsors, the Principal Investigator must notify Grants Management of the necessity of the no-cost extension, including the time needed and a project-specific justification of the extension. It is Grant Management's responsibility to notify the sponsoring agency and to make internal adjustments to the award. Extension requests of this type should be made to Grants Management no later than thirty (30) days prior to the project's termination.

Written requests for no-cost extension (for those agencies and awards where the Health Science Center has no delegated authority) must generally be made at least sixty (60) days before the end of the currently active budget period. Written requests should be generated by the Investigator and should include the reason why the extension is needed; the month, date and year that the Investigator expects to complete the work; and the amount of residual funds and how they will be used during the no-cost extension.

Change in Principal Investigator/Project Director
As a general rule, if a Principal Investigator/Project Director is absent from a project for a period three (3) months or more, a substitute PI must be proposed and approved by the sponsor. The PI must notify Grants Management and the sponsor's program officer at least thirty (30) days before departure or as soon as the expected absence is known.

Requests for change in PI should include a justification for the change, the curriculum vitae of the new proposed PI and any budget changes resulting from the change (such as differences in salary). The new proposed PI must also endorse the request as well as Grants Management.

Purchasing Procedures
Purchase of goods and services for sponsored projects must comply with both the Health Science Center policies and sponsor restrictions. Purchasing procedures as outlined in the Handbook of Operating Procedures should be followed in making purchases for sponsored programs just as for any other procurement. In addition, particular conditions of the award must be consulted. Some awards prohibit certain purchases, others may require advance approval of the sponsor. Advice on these restrictions is available from Grants Management. The allowability and allocability of any purchases made from sponsored funds and the time period of the award for which purchases are made and charged to the project should be considered. Any purchase of equipment or supplies must be made and charged within the period of the agreement. Purchases should be allocated to the appropriate sponsored project. If more than one award funds a research laboratory and the item will be used by one or more projects, the expense should be appropriately charged to each project.

Purchases Near to Termination Date
Items not received during the project period are not considered of benefit to the project and may be disallowed. Consequently, no purchase of equipment should be made later than sixty (60) days prior to the final termination date of an agreement.

Note that the government requires reimbursement for the cost of any supplies whose aggregate value exceeds $5,000 at the end of a project period. Good judgement should be used in order that supplies are purchased in quantities that can be consumed during the project period.

Equipment Purchases
The definition of equipment at the Health Science Center is an item having an acquisition cost in excess of $1,000 and a useful life of one year or more. Ideally, all equipment purchases are itemized and approved in the original proposal. Prior approval may be needed from the sponsor to buy equipment not previously authorized. As a rule, general purpose equipment such as computers or furniture will not be approved unless those items are used primarily or exclusively for the actual conduct of the program. Any requisition requesting general purpose equipment not itemized in the approved budget must include a justification from the Investigator. This justification must be retained in the academic department's records.

7.2 Purchasing Outside Services

That the consultant is doing work independently without supervision;

That the consultant has not been an employee of the Health Science Center within the last 12 months;

That the consultant is using his/her own facilities or equipment to conduct the work; and

That the consultant is not included on the list of excluded, suspended, or other

wise ineligible for participation in federal programs.

Note:

A subaward issued from Grants Management is normally for substantive work (e.g., the subawardee is responsible for programmatic decision making and its performance is measured against meeting the objectives of the project) A purchase order for services issued by Purchasing is normally for vendor services (e.g., the vendor is providing goods and services within their normal business operations). Grants Management and Purchasing can provide assistance on making the determination between a subawardee and a vendor.

Travel
The Health Science Center's travel policies are detailed in the Travel Operating Procedures . These travel policies and procedures apply to travel on sponsored program accounts unless the sponsor's policies are more restrictive. To be allowable, travel must directly benefit the project. The terms and conditions of the award will specify whether sponsor approval in advance (and in addition to approval on the approved budget) is required.

Foreign Travel
Foreign travel may require specific approval for each trip. As well, when using federal funds, American flag carrier restrictions will normally apply. Please consult Grants Management if foreign travel restrictions are unclear.

Property Management
Sponsors normally require that property purchased under sponsored agreements be used exclusively or primarily for the use of the sponsored project. Sponsors also differ in their vesting of title or reporting requirements. Some equipment acquired under a sponsored program will remain the property of the sponsor and should be managed accordingly. The Property Control Office (within the Office of Accounting) is responsible for the Health Science Center's equipment management system, including inventory, record keeping, sharing, audit, and disposition. Questions regarding property management should be directed to the Property Control Office at extension 7-5977.

Vesting of Equipment Title
In general and on most federal agreements, the Health Science Center is directly accountable for each item of equipment at the project termination. Under most federal grants, equipment is vested with the Health Science Center, the only exception being that certain agencies reserve the right to transfer the equipment following completion of the grant. This right is reserved to facility cases where the PI transfers to another institution and the Health Science Center has no further need for the equipment (see Section 7.5).

Surplus Property
It is expected that Investigators will not purchase equipment for use on sponsored projects that is already readily available, consistent with the needs of the project, at the Health Science Center. The Investigator should assure him or herself that any equipment to be purchased is needed by the project and cannot be shared with other investigators.

The Health Science Center has a surplus property program whose listings should be consulted prior to making purchases on any sponsored programs account to assure that the equipment is not already available on campus. Section 7.1.10.3(b) of the Handbook of Operating Procedures describes the Health Science Center's surplus property program.

Transfer or Disposition of Equipment
There are numerous regulations regarding the transfer or disposition of property. These regulations vary under differing circumstances of ownership (title), original cost, source of funds, and current market value. For information regarding the transfer or disposition of equipment, contact either Grants Management or the Property Control Office.

Intellectual Property
If at any time during the course of a sponsored project it is determined that there may be a potentially patentable invention or discovery, it is important to contact the Office of Intellectual Property Administration (OIPA). Generally, an invention disclosure is submitted to and reviewed by the OIPA in accordance with Health Science Center policies and an ultimate decision is made with respect to pursuing patenting and licensing. Many sponsored program agreements required the submission of an invention disclosure report within a relatively short time frame. OIPA is responsible for submitting any disclosure or other periodic invention reporting required to the sponsor.

A copy of the Health Science Center's intellectual property policy is available in the Office of Intellectual Property Administration and can also be located at http://www.utsystem.edu/ogc/intellectualproperty/2xii.htm. Questions that arise with respect to intellectual property developed during the course of a sponsored agreement should be directed to the Office of Intellectual Property Administration at extension 6364.

Publications
Investigators are expected to publish results of their research and scholarly activities. This right should be retained in all sponsored agreements. Credit should normally be given to the source of support of the project through an appropriate footnote; however, specific instructions in each grant, contract, or other agreement will govern. Under federal grants and contracts, all reports or papers submitted for publication should also contain this statement: "Reproduction in whole or in part is permitted for any purpose of the United States Government." Some sponsors require prior or simultaneous submission of papers or abstracts to the sponsor for review and comment; the award document should be consulted for specific requirements.

Research Data * 1
Principal Investigators and Project Directors should be familiar with the Health Science Center and faculty obligations and responsibilities regarding Access to and Retention of Research Data which can be found at Appendix J.

Freedom of Information
In addition to certain State of Texas statutes guaranteeing the right of access to information about public agencies, the federal Freedom of Information Act (FOIA) is applicable to federally funded projects. With limited exceptions, Health Science Center records such as policy documents and funded research proposals must be disclosed to the public upon request. There are only certain exceptions such as proprietary data or confidential salary information that can be withheld from disclosure.

Normally, FOIA requests are directed from federal agencies to Grants Management. Grants Management will contact the Principal Investigator to inform him or her of the request and to ascertain whether there is any proprietary information that should be withheld. Grants Management, as a standard practice, will request deletion of any budgetary information prior to release.

7.4 Reporting Responsibility 1

Delinquent Reporting
Failure to submit reports in a complete and timely manner can delay payment for final project expenses and favorable consideration of pending proposals. Some sponsors will not only withhold future awards to individual delinquent faculty, but also to any other Health Science Center faculty member anticipating funding from that same sponsor.

IMPORTANT

The Health Science Center considers timely reporting essential to the proper stewardship of sponsored funds. Therefore, Grants Management, upon consultation with the appropriate Department Chair and Dean, may withhold sign off on any new proposals for faculty who are seriously delinquent in their technical reporting responsibilities.

Final Technical Reports
Some sponsors require use of their own forms for final technical reports. These forms are available either in the sponsor's application packages, with the award documents, or on-line via the internet. Follow the sponsor's instructions for the preparation of final technical reports, which normally include a list of publications resulting from the sponsored project.

IMPORTANT

A copy of the face page of the final report or its transmittal letter should be forwarded to Grants Management for its records.

Final Invention Report
Grants Management will send copies of the appropriate final invention report or a certification form to the PI/PD. The PI/PD must complete and return the form to Grants Management who will then transmit it to the sponsoring agency.

Final Financial Reports
In general, the Office of Grants Management prepares final financial reports. Such reports will be submitted to the principal investigator/project director or academic department in draft form for review and comment prior to their submission to the funding agency; an exception to this policy is made in the case of federal financial reports. Expenditures against terminating accounts should be processed as early as possible and arrangements should be made to move personnel and other on-going charges to another appropriate account.

There are some instances where a particular department or program is responsible for preparation of the final financial report. Those instances will be noted on the New Account Memorandum. Final financial reports prepared at the department or program level should be submitted to Grants Management for review and signature prior to their submission to the funding agency.

Final Property Reports
The Office of Grants Management will coordinate with the Property Control Office preparation and submission of property reports required by the sponsor. If title to property acquired under a sponsored agreement vests with the sponsor at time of completion and the Principal Investigator/Project Director wishes to have the title transferred to the Health Science Center, a request should be made to the Office of Grants Management who will prepare the necessary request to the funding agency.

Deficits and Surplus Balances Upon Account Closeout
When projects are ended and all reports have been submitted, it is not uncommon for there to be a positive or negative balance in the account. Disposition of those balances will be made as follows:

Deficit Balances
Sponsored project accounts should be administered in a manner that avoids deficit balances. Rarely do sponsors allow a transfer of a deficit balance to a new project period. Under very unusual circumstances, and with adequate justification, some agencies will allow institutions to transfer a deficit balance from one budget period to the next, within the project period only. In these situations, the estimated deficit carry forward must be stated in the progress report or continuation application.

Deficit balances should be resolved as soon as possible after the project period ends. These balances are the responsibility of the project director and his or her department and should be written off to non-sponsored program accounts. Deficit balances cannot be transferred to accounts funded with state appropriations.

Note:

The transfer of individual costs from one sponsored project account ("K") series to another where the sole purpose is to offset over-expenditures is unallowable. Transfers can only be made when the charge clearly is allocable to the new account and within the limits of the cost transfer policy (see Section 6.5).

Surplus Balances
There may be cases when positive account balances may be retained by the Health Science Center at the end of a project. If agency and agreements regulations allow such retention, Grants Management will work with the academic department in determining an account to which the surplus balance may be transferred.

Original ledger sheets, purchase orders, invoices, payroll records and other official documents are retained by central Health Science Center administrative offices. Departments must retain original copies of budget documentation, expenditure statements signed by the Principal Investigator/Project Director, personnel files, account reconciliation, and all other source documents and invoices that are used to charge costs on a grant or contract for a period of at least three years following final close-out of a grant and six years following final closeout of a contract.

For information about retention of technical data, see Appendix J.

7.6 Transfer of Investigators to Other Institutions 1

Equipment purchased with agreement funds in which the faculty member served as the primary investigator may be authorized under the following conditions:

1. It must be established that the equipment was brought to the Health Science Center or that the equipment was purchased from grant funds for which the faculty member was listed as the principal investigator.
2. The awarding agency that provided the funds must agree to the transfer, either through its published policies or by specific written approval.
3. The faculty member must be relocating to another educational institution that will accept title to the equipment and pay the shipping charges involved.
4. The department chair or dean certifies that the loss of the equipment will not jeopardize the research or scholarly activities of other members of the department and that funds for replacement of the equipment will not be requested if the transfer is authorized.