Post-Award Grants Manual

This electronic Grants Manual is designed to support Principal Investigators (PIs) and Grant Managers in overseeing external funding. While the College serves as the legal recipient and remains accountable to the sponsor, the PI and Grant Manager hold primary responsibility for the project’s fiscal management and overall conduct.

Business Office Contact Information

Susan Benson
507-222-5990

On this page:

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

Federal grants are strictly regulated by the Office of Management and Budget (OMB) under the Uniform Guidance, found in Title 2 of the Code of Federal Regulations (2 CFR 200). Officially established in December 2014 by the Council on Financial Assistance Reform, comprehensive revisions took effect on October 1, 2024, as part of OMB’s statutory five-year review process to streamline federal financial assistance.

Principal Investigators must adhere to the specific version of the Uniform Guidance incorporated into their individual Notice of Award. The full text is available on the Federal Register website.

Additional Information

Pre-Award: Grant Proposals Guidelines

Proposals for grants of all types must be initiated through the Grants Office. Refer to their Forms & Templates page for assistance with the proposal submission process.

Direct and Indirect Costs

Direct costs (200.413) are expenses that can be directly tied to a particular project or activity and are allowable under all applicable terms and conditions. Examples include grant personnel salaries, wages and fringe benefits, materials and supplies, equipment, and travel.  Indirect costs charged to federally funded grants represent reimbursement to the College for those costs that are not directly tied to a specific project but are essential for the overall operation of the organization. These include expenses such as administrative costs (e.g., salaries of administrative staff, rent, office supplies), general expenses (e.g., accounting, legal, and human resources), and facilities and administrative costs (e.g., maintenance, lights, heat, space utilization, depreciation, utilities, insurance). Indirect costs may not be claimed as direct costs on a grant.

The indirect cost rate (200.414) is negotiated by the Business Office with the Department of Health and Human Services following a prescribed formula. Our current indirect cost rate (IDC) has been approved at 60.0% for federal grants awarded on July 1, 2023, through June 30, 2027. Our approved rate will remain in effect until it is amended. The IDC rate in effect at the time of the initial awarding of a grant is in effect throughout the life of the grant.

When a grant is awarded, the approved IDC rate is assigned. As applicable direct costs are charged to the grant, Workday automatically applies the pre-determined indirect cost rate to those direct costs. The indirect costs are then added to the grant’s total expenses. The negotiated rates must be accepted by all Federal awarding agencies (§200.414). Exceptions are allowed only when required by Federal statute or regulation or when approved by a Federal awarding agency head or delegate based on publicly documented justification.

Fringe Benefits

All grant proposals including salaries or stipends must include a corresponding line item for fringe benefits. For budgeting purposes, a standard institutional average of 36% is applied to all part-time and full-time employee salaries. For faculty research and student work performed during academic breaks, a rate of 7.65% (FICA) should be used.

These uniform percentages are applied across all grants regardless of type or size to ensure equitable budgeting and provide adequate coverage for the actual fringe benefit costs that will be charged to the award. These rates are subject to change based on fluctuating institutional benefit costs. Some funders restrict indirect costs, cap total charges, or prohibit charging benefits. Despite these limitations, please include all anticipated research or program costs in your proposed grant budget, even those that will be covered by college funds or non-federal matching grants. Seeing the full scope of anticipated costs allows the College to make an informed decision regarding the proposal.

Upon Receipt of a New Grant

First-time grant recipients are required to attend a grant orientation meeting with the Business Office and Grants Office. The orientation provides an opportunity to discuss the grant award, reporting requirements, policies and procedures, and to familiarize the new Principal Investigator (PI) with the resources available. If other personnel will assist with management of the grant, they should attend the orientation as well.

Once the College receives the official award notification, the Grants Office and Business Office collaborate to establish the award in Workday. All expenditures and financial activities are tracked under a unique grant worktag. The Principal Investigator (PI) and any authorized personnel will be granted online access to monitor grant activity in real time. Throughout the life of the grant, the Business Office oversees financial administration to ensure alignment with standard accounting practices, College policies, and federal regulations, while both offices provide ongoing compliance support and guidance to the PI.

Principal Investigator’s Responsibilities

The Principal Investigator is responsible for the proper fiscal management and conduct of the project. The PI must:

  • Read, understand, and comply with all terms and conditions imposed by the sponsor and the College.
  • Manage project funds efficiently within approved budgets, authorizing only allowable expenses.
  • Monitor grant activity and budget availability in Workday on a regular basis.
  • Ensure expenditures do not exceed the total authorized funding for the project period.
  • Charge project costs directly to the appropriate project account and avoid retroactive cost transfers.
  • Initiate required approvals for all subsequent budgetary and programmatic changes.
  • Prepare and submit required programmatic reports in a timely manner.
  • Include comprehensive documentation with all payment requests, including receipts and detailed descriptions of the purchase.
  • Certify the accuracy of grant activity and budget availability on a quarterly basis.
  • Certify Effort for all applicable personnel.

Budget and Expenditure Reporting

To facilitate effective budget management, PIs are given electronic access to their grant activity in Workday via the Grant Budget vs. Actual report or the Budget Reporting app. The PI must authorize all spending from the grant and is encouraged to monitor activity on a monthly basis. Discrepancies should be communicated immediately to the Business Office for resolution. 

For federally funded grants, Carleton College requires a quarterly review and certification of grant budgets and expenditures. The certification forms are initiated by the Business Office and are recorded via the OnBase Workflow process. Carleton’s fiscal quarters are as follows:

Q1 – July to September, Q2 – October to December, Q3 – January to March, Q4 – April to June.

Salary and Wages for Faculty, Staff, and Students

To ensure proper worker classification, please contact Human Resources prior to hiring any new employee or independent contractor. Independent contractors or consultants provide temporary, specialized services and require a completed Independent Contractor Evaluation Form (found under HR Recruitment Forms) before any work begins. Individuals hired as employees on a College-administered grant must fully complete the mandatory new employee orientation with Human Resources.

Faculty Summer Stipends & Research Salary

Faculty budgeted to receive summer stipends must request their payment in Workday using the Request One-Time Payment for Myself task. Requests may be submitted ahead of time, provided the designated payment dates fall within the active performance period. Please note that if you are requesting more than one month of stipend, the total amount cannot be claimed in the first month; payments must be distributed across the performance period.

Summer salary for faculty research funded by the National Science Foundation (NSF) is calculated as a percentage of the academic year contract, typically 1/9 (one month) or 2/9 (two months). The requested amount must be identified in the approved grant budget. For detailed guidelines regarding Senior Personnel Salaries and Wages, please reference the NSA GAPPG period.

After-the-fact Effort Certification (required for federal grants) is obtained at least twice per year. See Effort Certification Reporting for more information.

Summer Student Research and Employment Information:

Workshops and Additional Compensation

Payments to faculty for work performed outside of their normal academic contract must be requested in Workday using the Request One-Time Payment task. Workshop stipends must be requested after the event has been successfully completed. Employees under a full-time contract with Carleton College are not eligible to receive additional compensation from government grants. Part-Time Exempt Staff are eligible for stipends only if the work or workshop occurs outside of their regularly scheduled work calendar. Faculty members who hold a split appointment between faculty and staff roles must contact Human Resources for guidance before requesting payment.

Effort Certification Reporting Requirements

Effort Report Certification: Guidance and Procedures

As a recipient of federal funding, Carleton College must comply with the Office of Management and Budget’s Uniform Guidance Subpart E §200.430, which requires certifying effort on sponsored awards. This guidance is provided to ensure all effort certifications are accurate, timely, and compliant with federal and sponsor regulations. Failure to comply can result in financial penalties, repayment of federal funds, and the loss of future funding eligibility.

Key Definitions

  • Effort: The percentage of an individual’s total professional time on all compensated activities, such as research, teaching, or administration, which must equal 100%. This includes time spent on sponsored projects, whether directly charged or part of committed cost share.
  • Committed Cost Share: The portion of effort on a sponsored project that is funded by Carleton College, not the grant. This is a legally binding commitment to the sponsor.
  • Effort Reporting: The formal process of documenting how an individual’s effort is distributed between sponsored and non-sponsored projects within a specific reporting period.
  • Effort Certification: The formal confirmation by an authorized individual that the reported effort percentages reasonably reflect the work performed. Effort is a reasonable approximation, not an exact accounting of hours.

Certification of Effort Reports

In compliance with Uniform Guidance, Carleton College uses an after-the-fact effort reporting process to ensure salaries charged to sponsored projects accurately reflect the work performed.

Effort reports display how an individual’s salary is distributed across sponsored and non-sponsored activities during a specified period. Certifiers must review reports and confirm the distribution reasonably reflects the individual’s actual effort, with the total reported effort equaling 100% of all compensated actives.  

  • Bi-weekly and student employee time is certified via electronic time sheets.
  • Workshop stipends and other one-time payments are not subject to effort reporting as they are considered compensation for participation, not effort. 

The Business Office initiates effort reporting twice per year: in the summer for the academic year and in the fall for summer salary. An email notification will be sent when reports are due. The frequency may be increased depending on grant activity or specific sponsor requirements.

Who Certifies Effort Reports?

Effort reports are certified by the Principal Investigators (PIs) or the employee (self-certifier) to ensure the certifier has first-hand knowledge of the work performed.

Roles and Responsibilities

Meeting federal compliance requires coordination among multiple stakeholders.

  • Principal Investigators (PIs)
    • Certify Reports: Promptly certify reports for your project.
    • Monitor Award Activity: Regularly review salary charges on your award and report any discrepancies to the Business Office.
    • Manage Committed Effort: Be aware of the levels of effort committed, charged, and reported for both yourself and your team.
    • Communicate Changes: Promptly report significant effort changes—generally a 25% or more change in committed effort for a key person—to the Grants and Business Offices.
  • Business Office
    • Initiate the effort certification process.
    • Monitor the completion and status of effort reports.
    • Provide guidance and support to PIs throughout the process.

Participant Support Costs (PSC)

Under the Uniform Guidance (§200.1 and § 200.456), PSCs are direct costs for items such as stipends, subsistence, travel, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences or training projects. Indirect Costs (F&A) are not allowed on PSC lines.

Role-Based Eligibility

  • Participants (Budget as PSC): Individuals whose primary purpose is learning and receiving training.
  • Speakers/Trainers (Budget Elsewhere): Individuals whose primary purpose is to speak, present, or manage the event. Budget these as consultants, standard travel, or honoraria.
  • Federal Employees: Eligible only if there is zero duplication of funding and no single expense is split between the NSF grant and their parent agency.
  • Excluded: Project employees, and any trainees receiving compensation from other federal sources.

Expense Rules & Restrictions

  • Allowances: Must be reasonable, follow Carleton policy, and cap at actual event days plus travel time. Per diems must be reduced if meals/lodging are provided or covered by registration fees.
  • Local Attendees: May join group meals/coffee breaks, but cannot receive individual per diems or lodging.
  • Travel: Must utilize economy-class accommodations and comply with the Fly America Act (U.S.-Flag air carriers). Training-related field trip transportation is allowed.
  • Prohibited Proximity Costs: Room rentals, catering, conference supplies, and research subject incentive payments/gift cards cannot be charged to PSC.
  • Funds budgeted for PSC are locked and cannot be reallocated to other budget lines without prior approval from the funding agency.

NSF Participant Support Costs Resources

Procurement, Suspension, and Debarment Requirements for Federal Grants

Carleton College is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred by the federal government. 

Suspension – A disqualification from government contracting and subcontracting for a temporary period of time because a company or individual is suspected of engaging in criminal, fraudulent, or seriously improper conduct. Suspension is to be used on an interim basis pending debarment proceedings.

Debarment – An exclusion from government contracting and subcontracting for a reasonable, specified period of time because an individual or supplier failed to perform or their performance was inadequate.

The College will assure compliance with this federal regulation with confirmation from the System for Award Management (SAM). SAM will be checked before making a subaward or contract award of any amount to an outside organization. Third-party payments associated with federal grants will be reviewed against SAM prior to payment of $25,000.00 or more (2 CFR § 180.220). The Business Office should be contacted before entering into a subaward or contract arrangement.

A Supplier Selection Form is required to be submitted for good or services of greater than $15,000 which will include the SAM check.

While many of the key requirements are outlined below, it is important to fully read the procurement sections of the Uniform Guidance, (Subpart D §§ 200.317-327), to ensure compliance.

Some of the general standards over procurement include:

  • Every non-federal entity receiving federal awards must have documented procurement procedures that reflect federal law, Uniform Guidance standards, and any state regulations.
  • Entities should focus on the most economical solution during the procurement process, and must avoid using federal funds for the acquisition of unnecessary items. Organizations are encouraged to consider the use of shared services and intergovernmental agreements to foster greater economy and efficiency.
  • Written conflict-of-interest policies are required. No employee or agent of the entity may participate in the selection, award, or administration of a contract funded by federal grant dollars if he or she has an actual or apparent conflict of interest.
  • The organization must document the procurement steps and activities required to be completed. This includes the basis for the type of procurement, contract type, and the basis for the contractor selection and price.
  • Ultimately, the recipient of federal awards must maintain an appropriate level of oversight to ensure that contractors perform in accordance with the terms of their contract.

Methods of Procurement

  1. Micro-purchase (200.67): The purchase of supplies or services where the aggregate dollar amount does not exceed $15,000. When practical, micro-purchases should be distributed among qualified suppliers and may be awarded without solicitations if the price is considered to be reasonable (2 CFR 200.320, FAR 2.101).
    • Use professional judgment to identify reliable suppliers.
    • When available, prioritize vendors offering Carleton discounts.
    • Installment payments or multiple transactions under the aggregate threshold that are part of a single, larger purchase are not considered micro-purchases
  2. Small purchase (Simplified Acquisition Threshold): The acquisition of supplies, services or equipment with an aggregate cost between $15,001 to $350,000 (2 CFR 200.320, FAR 2.101) Price or rate quotations must be obtained from an adequate number or qualified sources prior to making a purchase to ensure fair and competitive pricing.
    • Documentation for at least two price quotes to support the supplier selection must be submitted to the Purchasing Manager prior to making the purchase. 
    • Documentation must be in writing. Acceptable formats include supplier quotes, website screenshots, published price lists, or advertised pricing from established journals.
    • If you cannot obtain an adequate number of quotes please contact the Purchasing Manager for assistance.
  3. Sealed bids (formal advertising): For acquisitions exceeding $350,000, bids must be publicly solicited from an adequate number of known suppliers. A firm fixed-price contract is awarded to the lowest responsive and responsible bidder.  
  4. Competitive proposals (requests for proposals): Used for purchases exceeding $350,000, when conditions are not appropriate for sealed bids. This process is conducted with more than one source submitting an offer, and either fixed price or cost-reimbursement contracts is awarded. The contract should be awarded to the firm whose proposal is most advantageous to the project, with price being one of the factors considered.
    • Please contact the Purchasing Manager for assistance with the competitive proposal process.
  5. Noncompetitive proposals (sole source): Noncompetitive procurement is the method of soliciting a proposal from only one source and can be used only when one or more of the following circumstances apply:
    • The aggregate dollar amount of which does not exceed the micro-purchase threshold ($15,000).
    • The item is available only from a single source.
    • The public exigency or emergency will not permit a delay resulting from competitive solicitation.
    • The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from Carleton.
    • After solicitation of a number of sources, competition is determined to be inadequate.

The following rules apply to all purchases:

  1. The purchase must comply with Carleton’s documented procurement procedures
  2. The purchase must be necessary to carry out the Federal award
  3. The purchase must be made with open competition to the extent required
  4. The purchase is in compliance with Carleton’s conflict of interest policy
  5. The purchase documentation contains sufficient and proper history of the purchase

Cost Principles and Allowable Expenses

Allowable, Reasonable, and Allocable are the basic considerations for whether a cost can be included in a budget for a Federal award. Though these principles may change depending on the project, they must be used to determine whether the costs are appropriate for a sponsored project. The cost principles relating to expenditures on federal awards are contained in the OMB Uniform Guidance (UG), Subpart E, 200.400-409. 

Consider the following cost principles when deciding if a cost is allowable:

Cost Principles: Allowability (200.403)

  • Is the cost reasonable and necessary for the program?
  • Is the expense in compliance with laws, regulations and grant terms?
  • To what extent is the expense allocable to the grant?
  • Is the cost adequately documented?
  • Is it consistent with grantee rules that apply to both Federally funded and non-Federally funded activities?

Cost Principles: Reasonable (200.404)

  • A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.
  • Consideration: Do sound business practices support the expenditure?

Cost Principles:  Allocable Costs (200.405)

  • Allocable means the good or service can be assigned to an award or cost objective in accordance with the relative benefit achieved.
  • If a cost benefits two or more projects, activities, or programs in proportions that can be determined without undue effort or cost, the cost should be allocated to the projects based on the proportional benefit.

While UG provides thorough guidance, some excluded items to note are:

Unallowable Expenses (200.410-200.411):

Federal regulations prohibit certain costs from being charged to federally sponsored awards. Uniform Guidance Subpart E provides a detailed listing of items that are typically unallowable. Examples of costs normally considered unallowable include:

  • Alcoholic beverages (200.423)
  • Contributions and donations (200.434)
  • Entertainment costs (200.438)
  • Fines and Penalties (200.441)
  • Personal expenses or purchases (200.445)
  • Lobbying (200.450)
  • Participant support costs not specifically addressed in your award letter
  • International travel costs not specifically addressed in your award letter

Grant expenditures are processed through Accounts Payable and are reviewed to ensure they are allowable, within the allowed time period, properly authorized and adequately documented. If the invoice does not provide adequate information as to the nature of the charge and how it relates to the grant, please supply other supporting documents or narrative.

The following policies have been provided in order to provide clear guidance as to what costs constitute appropriate charges to federally funded projects, as well as to achieve consistency with college policies.

If an unallowable expense or cost overrun is discovered during the Grant Manager’s quarterly grant review, the Grant and Cash Manager will work with the principal investigator to identify an alternate internal funding source (i.e. overhead account, faculty development account, PI’s home department), and a cost transfer will be initiated.

Additional Related College Policies

Additional Awarding Agency Regulations:

Travel and Related Expenses (200.474 & 200.475)

Domestic and foreign travel must follow these guidelines as well as Carleton’s Employee Travel and Reimbursement policy, whichever imposes the greater restrictions, if travel is allowed on the grant. 

Lodging and Subsistence

Costs incurred for travel, including lodging, other subsistence, and incidental expenses must be considered reasonable and otherwise allowable only to the extent that such costs do not exceed charges normally allowed by Carleton in its regular operation as stated on the college’s travel policy. 

Air Travel

Federal regulations require travelers to incur the lowest possible expense to the federal award; in most circumstances, this is a non-refundable (restricted) economy class airfare.

Federal regulations require that airfare costs in excess of the lowest economy fare class are unallowable except when such accommodations would:

  • Require circuitous routing;
  • Require travel during unreasonable hours;
  • Excessively prolong travel;
  • Result in additional costs that would offset the transportation savings; or
  • Offer accommodations not reasonably adequate for the traveler’s medical needs.

Once these criteria are met, the traveler must justify and document the exception for the use of business-class or upgraded economy airfare to be allowable on a federal award. Complementary (no-cost) upgrades are allowed.

Foreign travel using federal funds must have prior approval from the sponsoring agency, and airfare must be purchased on an American flag carrier (Fly America Act). One exception to this requirement is transportation provided under a bilateral or multilateral air transport agreement, to which the U.S. government and the government of a foreign country are parties, and which the Department of Transportation has determined meets the requirements of the Fly America Act.

The U.S. government has entered into several air transport agreements that allow federal funded transportation services for travel and cargo movements to use foreign air carriers under certain circumstances. There are currently four bilateral/multilateral “Open Skies Agreements” (U.S. Government Procured Transportation) in effect. Information on the four Open Skies Air Transportation Agreements (U.S. Government Procured Transportation) and other specific country agreements may be accessed via the Department of Transportation’s website.

Equipment

The Principal Investigator is responsible for purchasing equipment in accordance with Federal regulations and College purchasing policy. 

For equipment purchases between $10,001 to $250,000, the Supplier Selection Form must be completed and three bids provided prior to making the purchase. (This may have been completed during the grant proposal stage.) Documentation needs to be in writing from the suppliers and can include screenshots from websites, copies of published price lists, or advertised pricing in established magazines or journals.

There may be situations where there is a sole source provider of the equipment. This must be documented and approved. Convenience, a good deal, or poor timing are not reasons for bypassing the bid process. Computer purchases up to $5,000 are considered supplies and do not require the bid process.

Equipment purchases greater than $250,000 require bids or competitive proposals unless there is a documented sole source provider. All purchases of this size should be reviewed by the Purchasing Manager.

200.1 Equipment means tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the recipient or subrecipient for financial statement purposes, or $10,000.

200.313 Equipment Title. Subject to the obligations and conditions set forth in this section, title to equipment acquired under a Federal award will vest upon acquisition in the non-Federal entity.

The College will tag new equipment and perform physical inventories once every year.

See also 200.439 Equipment and other capital expenditures. 

Disposal of Equipment

The OMB Uniform Guidance, section 2CFR 200.313 and 200.439, address the various types of property that may be acquired with federal funds.  Equipment means tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost that equals or exceeds the lesser of the capitalization level established by the recipient or subrecipient for financial statement purposes, or $10,000. If the recipient no longer has a need for the equipment, the recipient shall request disposition instructions from the College Purchasing Manager.  For more information regarding the disposal of equipment, please see the Property Disposal policy in the College Handbook.

Cost Sharing (200.306)

Cost sharing or matching is that portion of a total sponsored project’s costs that are paid from sources other than the funds provided by the sponsor.  Cost sharing or matching agreements should be approved during the proposal stage. After the grant is awarded, it is useful to meet with the Grant Manager and those “contributing” to the match to clarify what form the match will take, and the timeline over which it will be provided. It is the Principal Investigator’s responsibility to verify and document that the match has been fulfilled. The documentation should be forwarded to the Grant Manager in the Business Office for review. The basic cost allowability test for the cost share or match (non-federal share of expenses) per OMB Uniform Guidance, part 200.306, includes the following:

  • Are verifiable from the recipient’s records
  • Are not included as contributions for any other federally-assisted project or program
  • Are necessary and reasonable project expenditures
  • Are allowable under applicable cost principles
  • Are not paid by the Federal Government under another award except where authorized by Federal statute to be used for cost sharing or matching
  • Are provided for in the approved budget when required by the Federal awarding agency
  • Conform to other provisions of Circular A-110, as applicable

The non-federal share of grant expenses must be identified and supported by documentation, which may be obtained from the following:

  • Evidence of cash received (sources, deposit)
  • Evidence of expenses (payroll, Effort Reports, Purchase orders, invoices, etc.)
  • Volunteer services (Effort Reports to the extent feasible)

Cost Transfers and Audit Red Flags

A cost transfer is an after-the-fact journal entry that transfers an expense onto a federally funded award that was previously charged to a different account. All costs should be charged to the appropriate federal award when first incurred, however, there may be circumstances when transfers may not be avoided.

Principal Investigators (PIs) have the primary responsibility for ensuring compliance with federal regulations, as well as monitoring expenditures, the proper allocation of expenses, and the timely detection and correction of errors.

To comply with the cost allowability and allocability requirements outlined in the Uniform Guidance (200.400 – Subpart E – Cost Principles) , the college must be able to explain and justify all charges transferred onto federal awards. Any necessary cost transfers should be completed in a timely manner and with a complete explanation per the principles outlined in the Uniform Guidance critical factors in supporting allowability and allocability. The following guidelines apply:

  • Explanation of cost transfer must be clearly stated and sufficient for an independent federal reviewer to conclude that it is appropriate. Simply stating that the transfer is to correct an error, or to move an expense to a correct account, is not sufficient
  • Cost transfers must be approved by the PI.
  • Transfer to grant accounts should be requested within 90 days of the expense (inappropriate expenses to a grant can be removed without a deadline)
  • Transfer to a grant made over 90 days from the original posting date must include supporting documentation explaining why the charge is allocable, allowable and reasonable  
  • Cost transfers that affect payroll where effort certification applies require a revised certification form to be completed by the affected employee
  • Cost transfers made solely for the purpose of spending down grant funds are not allowable

Procedure for processing cost transfers:

  • Cost transfer requests should be emailed to the Grant and Cash Manager in the Business Office.
    • Provide detail description and attached supporting documentation as needed
  • Cost transfers are reviewed and entered by the Grant and Cash Manager. Supporting documentation provided will be uploaded and linked to the journal. Approval is then routed to the Principal Investigator (PI), and the Comptroller. Once the approvals have been obtained, the journal will post to the ledger.

Although cost transfers cannot always be avoided, the following have been identified as audit red flags:

  • Excessive number of cost transfers
  • Transfers made near the end or after the project period has expired resulting in increased expenses
  • Transfers that give the appearance of moving deficits from one federal project to another
  • Transfers made with inadequate supporting documentation
  • Transfers made more than 90 days after the discovery of an error

Budget Changes in a Grant (200.308)

Most funding agencies permit changes in budgets up to a certain level without prior approval. Principal Investigators are expected to understand the budget limitations of their grants and request budget adjustments as needed.  Before requesting to move funds from one budget line to another, check the terms and conditions of the prime award to determine any established limits or restrictions. Prior approval from the sponsoring agency may be required for one or more of the following:

  • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval).
  • Change in a key person specified in the application or the Federal award. 
  • The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
  • The inclusion, unless waived by the Federal awarding agency, of costs that require prior approval in accordance with Subpart E—Cost Principles 45 CFR Part 75, Title 45, Appendix IX, “Principles for Determining Costs Applicable to Research and Development under Awards and Contracts with Hospitals,” or 48 CFR Part 31, “Contract Cost Principles and Procedures,” as applicable.
  • The transfer of funds budgeted for participant support costs as defined in § 200.75 Participant support costs to other categories of expense.
  • Unless described in the application and funded in the approved Federal awards, subawarding, transferring, or contracting out of any work under a Federal award. This provision does not apply to the acquisition of supplies, material, equipment, or general support services.
  • Changes in the amount of approved cost-sharing or matching provided by the non-Federal entity. No other prior approval requirements for specific items may be imposed unless a deviation has been approved by OMB. See also § 200.102 Exceptions and § 200.407 Prior written approval (prior approval).

All budget revisions must be coordinated with the Grants Office and the Business Office. The Principal Investigator will present the rationale explaining the necessity of the proposed budget justification, along with a revised budget and budget justification, to the Associate Director of the Grants Office and Compliance Officer. Once the Associate Director has reviewed the request for compliance with both the sponsor and college policy, the budget revision will be forwarded to the Grant and Cash Manager in the Business Office for review and approval. If approved by both offices, the budget revision submission will be initiated by the Associate Director of the Grants Office, as per awarding agency protocol. Budget revisions will be entered into the accounting system by the Grant and Cash Manager.

For more on prior approval, see § 200.407, and the Research Terms and Conditions Prior Approval Matrix.

Requesting a No-Cost Extension of a Grant

The sponsoring agency will provide the project period dates on the award document. As the project end dates approaches, the PI may wish to extend the project period to finish the project, providing grant funds remain. No-cost extensions may not be requested for the sole purpose of spending down remaining funds. Please contact the Grants Office for assistance when requesting a no cost extension.

NSF:
Grantee-Approved Extension: Grantees may authorize a one-time extension of the expiration date of the grant of up to 12 months if additional time beyond the established end date is required to assure adequate completion of the original scope of work within the funds already made available. This one-time extension may not be exercised merely for the purpose of using the unliquidated balances. Grantees are not authorized to extend an award that contains a zero balance. The grantee shall notify NSF, providing supporting reasons for the extension and the revised period of performance, at least ten calendar days prior to the end date specified in the grant to ensure accuracy of NSF’s grant data. All grantee-approved extension notifications must be submitted via use of NSF’s electronic systems. For grantee-approved extensions, no amendment will be issued. The revised end date can be viewed via NSF’s electronic systems.

NSF-Approved Extension: If additional time beyond the extension provided by the grantee is required and exceptional circumstances warrant, a formal request must be submitted via use of NSF’s electronic systems. The request must be submitted to NSF at least 45 days prior to the end date of the grant. The request must explain the need for the extension and include an estimate of the unobligated funds remaining and a plan for their use. As indicated above, that unobligated funds may remain at the expiration of the grant is not in itself sufficient justification for an extension. The plan must adhere to the previously approved objectives of the project. All requests for NSF-approved extensions must be submitted via use of NSF’s electronic systems.

The first no-cost extension request will be subject to the approval of the cognizant NSF Program Officer. The Grants Office and PI will be electronically notified of the disposition of this request by the cognizant NSF Program Officer. The second no-cost extension will be subject to the approval of an NSF Grants and Agreements Officer, and, if approved, will be in the form of an amendment to the grant specifying a new end date. Grantees are cautioned not to make new commitments or incur new expenditures after the end date in anticipation of a no-cost extension.

Two-Year Extensions for Special Creativity:  A Program Officer may recommend the extension of funding for certain research grants beyond the initial period for which the grant was awarded for a period of up to two years. The objective of such extensions is to offer the most creative investigators an extended opportunity to attack adventurous, “high-risk” opportunities in the same general research area, but not necessarily covered by the original/current proposal. Awards eligible for such an extension are generally continuing grants. Special Creativity Extensions are normally initiated by the NSF Program Officer based on progress during the first two years of the grant; PIs will be informed of such action a year in advance of the end date of the grant. In response to the Program Officer’s recommendation, the PI should submit the required information via the supplemental funding request module in NSF’s electronic systems.

NIH:
The eRA Commons’ No-Cost Extension feature allows the grantee organization to electronically submit a notification that the organization plans to use its one-time authority to extend the final budget period of a project period of a grant. This extension is without extra funding and available for up to 12 months of additional time, provided the Notice of Award does not prohibit the extension and the project’s approved scope will not change. Use of eRA Commons to submit No-Cost Extensions is required.

Note that the No-Cost Extension may be requested only by the Signing Official, no earlier than 90 days before the end of the project period and no later than the project’s end date. An email is sent to the funding agency’s Grants Management staff when a Signing Official submits the extension. The awarding office will revise the project period end date and send a confirmation to the grantee.

Cash Management

The federal government allows grant recipients to draw down funds electronically. Carleton College draws down grant funds after costs have been incurred for grant-related expenditures. Note: In accordance with Department of Treasury regulations, federal cash must be drawn solely to accommodate your immediate needs on an “As Needed Basis Only” and must not be held in excess of three (3) working days. The following is the cash management procedure:

  • PIs approve all allowable grant expenditures. Carleton pays for the approved expenditures through established accounts payable and payroll processes.
  • Grant expenditures are coded with unique Workday grant worktags that separate them from other college expenditures.
  • NSF: Fund drawdowns are prepared by the Grant and Cash Manager, approved by the Comptroller, and drawn by the Grant Manager or Senior Accountant via Research.gov
  • NIH/CNCS/NASA: Fund drawdowns are prepared by the Grant and Cash Manager, approved by the Comptroller, then drawn by the Grant Manager via Payment Management Systems.
  • DOE: PELL, Direct Loan and SEOG draws are regularly requested from Student Financial Aid to the Grant Manager to draw via G6.gov. TRIO and CWS expenses are also evaluated to determine if fund draws are necessary. The payment request is approved by the Comptroller, then drawn by the Grant Manager or Senior Accountant.

Grant-Related College Policies

Additional Resources