Post-Award Services provides support to Principal Investigators, deans, department chairs, administrators, and other campus officials in the administration of grants, contracts, and agreements. Located in the Office of Sponsored Programs (OSP), Post-Award Specialists are assigned to each UWM Division/School/College or department to serve as the primary point of contact and to help facilitate the overall post-award process while balancing the need for institutional and sponsor regulatory compliance.
Financial and Project Management
Award management is a shared responsibility between the Office of Sponsored Programs, the Principal Investigator (PI), and the PI’s Division/School/College or unit. The process shares responsibility for award management and ensures that, as a grant recipient, UWM is a responsible steward of the sponsor’s resources.
Award Terms and Conditions Determine Costs if Costs are Allowable
The grant agreement or contract usually contains the terms and conditions for receiving reimbursement. During the award acceptance process, you will receive a copy of the agreement. Please contact the Post-Award Specialist大奖娱乐官方网站主页 assigned to your Division/School/College with any questions regarding financial management of the award.
For most federal and non-federal awards, your Post-Award Specialist will initiate electronic drawdowns for funds or invoice to reimburse the University for expenses posted to your project on a monthly or quarterly basis (as determined by the sponsor). In most cases, invoices are submitted with expenses by budget category. The account codes used when expenses are posted to the project will dictate which budget category an expense will appear. Please be certain to use the proper account codes. Certain sponsors also require a detailed listing of expenses accompany each invoice (or if there is a question).
It may be essential that you obtain permission from the sponsor to deviate from the approved budget. Without sponsor prior approval, the sponsor may not be obligated to reimburse expenses that are not allowed. In the event of an audit or review of expenses by a sponsor, the division/school/college may be required to return funds to the sponsor if expenses are determined as unallowable. Your Post-Award Specialist大奖娱乐官方网站主页 will be contact with the PI, the division/school/college, and department if there are any audit or collection issues.
Fiscal Policies that Determine if Costs are Allowable
In addition to specific terms and conditions for fiscal management contained in an award document, most sponsors require that costs adhere to the guidelines provided by the Federal Office of Management and Budget (, 2 CFR 200.
Allowable costs MUST:
- Be necessary: A cost must be necessary to accomplish the scope of work and the cost applied must be essential to achieve a certain result or results. Be certain that purchases near the end of a project period, especially those for supplies and equipment, are necessary to accomplish the scope of work for that project. The last expenses charged to a project are most likely to be reviewed by sponsors.
- Be reasonable: A cost is reasonable if the good or services acquired reflect action that a “prudent person” would take acting in good judgement and the cost incurred is considered fair and does not deviate from established practice and policies of UWM.
- Be allocable: A cost is allocable if the goods or services are chargeable or assignable to an award in accordance to the benefit received. The cost must have been incurred specifically for the award, the cost must be necessary for the overall operation of UWM and can be distributed proportionally to the award using a reasonable method.
- Conform to the limitation specified in the specific award: It is critical for PIs and division/school/college administrators to review the award documents and other sponsor policies referenced in the award to fully understand which costs are allowed and which are not.
- Be consistent with University policies and procedures: Uniform Guidance requires that all project costs are treated consistently with policies and procedures applied to federal and non-federal projects. Pay close attention to procurement and travel policies. Links to relevant University policies follow below. Please contact your Unit Business Representative (UBR) with any questions regarding University policies and processes. For unique costs to your specific project, please verify the cost is allowable under University policy, the award terms and conditions, and under the Uniform Guidance (2 CFR 200).
- Not be included in the University’s indirect cost calculations: Any costs considered “overhead” included in : Accounting and Budget Control
- : Budget Transfers
- Purchasing Guidelines (ASM 3 Series)
Unallowable Costs: 2 CFR 200.402-410
大奖娱乐官方网站主页The does list a few items of cost that are not allowed on federal projects. Detailed requirements of selected items of cost are included in of the . The following are common items that are NOT allowed:
- Advertising, with detailed exceptions available in the regulations ()
- Alcohol ()
- Alumni Activities ()
- Commencement Costs ()
- Entertainment ()
- Fundraising ()
Costs not allowed will need to be transferred off the award. The division/school/college must initiate the cost transfer as soon as an unallowable expense has been identified. It is the responsibility of the division/school/college to provide the funding string for the unallowable expense that is consistent with University policies and procedures.
In some cases, a refund will need to be provided to the sponsor. Ultimately, it is the responsibility of the PI to monitor the expenses posted to projects and ensure costs are allowable. Your Post-Award Specialist is available to answer any cost-related questions.
Consultants and Professional Services
A consultant is an individual or entity providing professional advice or services for a fee, but normally is not an employee of the lead institution. Consultant charges must align with rates used from all sources of funding—both federal and non-federal. UW System employees may NOT be paid as consultants on any sponsored project.
大奖娱乐官方网站主页Consultants and professional services will be in the “other” budget category and will usually be included in your budget justification to the sponsor.
Consultants and professional services must be procured through the UWM Purchasing Department大奖娱乐官方网站主页. Prior to issuing a purchase order, the PI and/or their division/school/college/department is responsible for ensuring the vendor is not on the Federal Debarred list by checking the . The PI and/or their division/school/college/department will need to request the vendor’s DUNS number and conduct a search using the number. Retain the DUNS number and the search results in your file, including proof of negative results. If the vendor does not have a DUNS number, obtaining one is easy through .
Cost Transfers: 2 CFR 200.343(b)
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大奖娱乐官方网站主页 assigned to their Division/School/College to manage the cost-share commitment/documentation process.
The following are general statements regarding cost-share commitments:
- All cost-sharing must be provided during the performance period listed in the award documentation. Cost-sharing provided prior to or after the award period cannot be included in the official cost-sharing commitment.
- Proposals to federal agencies typically may not use federal sources of funds for cost-sharing (both mandatory and voluntary).
- All cost-sharing commitments must conform to the applicable federal principles (Uniform Guidance), and must be necessary, reasonable, and allocable to the project.
- Cost-sharing may be provided from a variety of sources, including campus funds, unrecoverable Facilities & Administrative Costs, volunteer contributions, third-party contributions (such as a for-profit entity), or other non-federal sponsored programs.
Cost overruns may occur during award administration. Although post-award administration is shared between the PI, dean, department chair, and OSP, it is ultimately the Division/School/College’s responsibility to oversee all sponsored program financial activity. To properly close accounts at the end of a project period (typically within 90 days of the project end date), the following procedure has been established to improve the fiscal management of sponsored programs at UWM and to reduce the risk of financial liability, fines, and/or disbarment:
- For any account that is overspent for three months following the project end date, funds will be transferred to a non-sponsored Division/School/College account to close the project account.
- Your Post-Award Specialist will work with the ), not with the individual PI. Equipment must be included in .
Indirect costs will not be applied to equipment. Equipment account codes include 4602-4604, 4620, 4630, and 4680. If your project includes constructing equipment, it is important that items used to create the equipment are charged to these account codes. Issues related to the sale or purchase of equipment purchased with federal funds may be directed to the UWM Purchasing Department or the Post-Award Specialist大奖娱乐官方网站主页 assigned to your division/school/college.
Materials and Supplies
Many sponsors allow no-cost extensions in the event that a sponsored program cannot be completed in the original award period. No additional funds will be provided to UWM during this period; it is simply additional time for the PI to finalize remaining project tasks. No-cost extensions typically are available for an additional 12 months.
No-cost extensions may NOT be granted in order to simply expend funds. All no-cost extensions must be appropriately justified within the context of the original scope of work and require approval from the co-PI’s大奖娱乐官方网站主页 dean and/or department chair. All no-cost extensions requests are reviewed by the Office of Sponsored Programs prior to submission to the sponsor.
大奖娱乐官方网站主页To initiate the no-cost extension request, the PI should e-mail their Post-Award Specialist with a clear justification statement of the need for an extension, summary of progress to date, and the new project end date proposed. The PI should also indicate whether the effort of key personnel on the project will remain the same or will change during the extension paid, and indicate the key personnel effort during the extension will be “sponsored paid” and/or “cost-shared.”
The timeframe for submitting no-cost extensions may vary, but generally must be submitted at least 90 days prior to the original project end date. Under no circumstances should a request for an extension be sent to the sponsor after the original project end date. PIs should carefully review their award terms and conditions regarding no-cost extensions.
Participant support costs are direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences or training projects. Participants may include recipients of training (not the provider), persons that perform no work or services for the project, students, scholars, scientists form other institutions, representatives from private companies, and teachers. Participant support is/are NOT human subject incentives, honoraria paid to a guest speaker or lecturer, or conference support costs.
Participant support may include stipends and travel expenses. In most cases, Facilities and Administrative (F&A) costs are not allowed on participant support. As a result, participant support is tracked as a separate project within an award. Any decrease in the participant support budget requires sponsor approval; see your award documents for specific details. Contact your Post-Award Specialist with specific questions regarding participant support costs.
Payments to Research Subjects
PIs 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 to PIs on particular challenges associated with various types of incentives.
大奖娱乐官方网站主页 have a default account code, which is often supplies. If the P-card is used for something other than supplies, the department or division/school/college must re-code the purchase. The PI or department must keep all receipts for purchases made on a P-card and all other University policies must be followed. At the end of the award, a P-card associated with a project must be re-assigned to another project to prevent charges outside of the project period.
Re-budgeting: 2 CFR 200.308
大奖娱乐官方网站主页Occasionally there may be a need to re-budget award funds to compensate for changes in costs (e.g., higher than expected increase in fringe benefits or venue location change), or changes to a specific line item, (e.g., participant support, or outgoing subaward). Most sponsors have regulations governing this process.
Any deviations from the awarded budget may need prior approval from the awarding agency. When requesting budget revisions, the same budget format is used as in the application unless the awarding agency has indicated another format. See 2 CFR 200.308 of the Uniform Guidance.
As soon as the need for the revision arises, please contact your Post-Award Specialist. They will ensure the budget revision request is reviewed for compliance and the proper approvals are received, both internally from the university, and externally from the sponsor. Also see Budget Development.
Annual (or Progress) Reports
Most multi-year projects require the PI to complete annual reports, which should describe the progress in all activities related to the project during each performance period.
- The annual reporting requirements are typically set forth in the award notification.
- PIs should carefully review the sponsor’s reporting requirements at award set-up and consult with the Pre-Award Specialist assigned to your Division/School/College for further clarification.
All projects typically require a final report. All sponsors have different requirements regarding the content and format of the final reports; thus, PIs should carefully review award materials to determine the final reporting requirements.
- If annual or progress reports are required as a condition of the award, the final report typically covers only the period between the last annual report to the end of the project.
- If no progress or annual reports are required, the final report will cover the entire project period.
- Final reports may include both a programmatic/research outo
Final reports may include both a programmatic/research outcome(s) summary and financial data. PIs should consult with the Post-Award Specialist assigned to their Division/School/College in advance of the report deadline to discuss what, if any, financial data is needed for the report.
Most sponsors request financial reports during the award period. Financial reporting requirements may differ from sponsor to sponsor. PIs should consult with the Post-Award Specialist大奖娱乐官方网站主页 assigned to their Division/School/College for assistance with developing and submitting financial reports.
A subaward allows a PI to support a project collaborator at another institution. Typically, a Pre-Award Specialist works closely with the PI to obtain the appropriate documentation for a subrecipient during the proposal development phase. At the time of award, OSP staff will contact the PI to confirm that a subrecipient will remain involved in the project.
OSP generates the subaward (and related documentation, if required) and provides a draft for the PI to review. Once the subaward is fully executed, the PI receives a final copy along with a Subcontract/Subaward Encumbrance Request. The request must be reviewed and approved by the PI and his/her Unit Business Representative.
大奖娱乐官方网站主页Many sponsored programs include funds for travel for project personnel. Here is an overview of travel issues that are common on sponsored programs; go to for a complete list of all current travel policies and procedures.
Air travel is typically limited to the lowest available coach fare. Effective 5 January 2015, all air travel must be booked via the using the Concur system or it will not be reimbursed. Concur uses an automated “lowest logical airfare” policy (which is a $150 tolerance threshold above the lowest rate) that allows users some flexibility in determining airlines, departure dates and times, and routes. For more information on reimbursable and non-reimbursable expenses, as well as other policy considerations, please review Purchase & Payment of Business Air Travel for more information.
Air Travel Using Federal Funds
If you are purchasing airfare with federal funds, the Fly America Act restricts your choice of airlines. Generally, researchers must use an airline owned by an American company (i.e., “flag carrier”), regardless of cost or convenience.
大奖娱乐官方网站主页Foreign carriers may be used for flights if a U.S. carrier “code-shares” with a foreign airline. A “code-share” occurs when two or more airlines “code” the same flight as if it was their own. For example, Delta and Air France code-share a flight to Paris, France. If the researcher’s boarding pass or e-ticket identifies the flight as a Delta flight, even if “Air France” is shown on the airplane, the researcher has met the requirements of the Fly America Act. However, if the researcher’s boarding pass or e-ticket indicates an Air France flight, the traveler is not in compliance with the Fly America Act and the trip cannot be reimbursed with the federal grant funds.
The U.S. government has entered into several air transport agreements that allow researchers using federal funds to use certain airlines in the European Union, Australia, Switzerland, and Japan. These agreements allow researchers to arrange air travel on foreign carriers in certain circumstances. Researchers who will travel to, from, or within these areas/countries, should contact the UWM Travel Office to discuss travel within these regions. Please be certain to indicate that the travel is associated with a federal grant or contract.
Exceptions to the Fly America Act
大奖娱乐官方网站主页Travelers are not required to use U.S. flag carriers in these circumstances:
- When there is no non-stop or direct service offered by a U.S. carrier.
- When travel outside the U.S. increases the number of plane changes to a destination by more than two.
- When the passenger’s total travel time is extended by at least six hours.
- When the connective time at an overseas interchange point is four hours or more.
Appropriate Modes of Transportation
大奖娱乐官方网站主页The approving authority has the responsibility to determine the most appropriate and cost effective means of transportation consistent with the authorized business purpose of the trip, and to consider all associated costs (e.g. employee work time, overnight lodging, meals, mileage).
For determining if vehicle transportation makes the most economical sense, or are the standard applications for calculating time and distance.
Researchers with disabilities or who require reasonable accommodations should contact the UWM Travel Office to discuss their options. An accommodation request may be needed prior to departure.
大奖娱乐官方网站主页The cost of attending conferences, workshops, symposiums, or other dissemination venues are eligible for reimbursement. Researchers should keep the receipts or other materials that document the registration fee associated with attendance.
The University’s maximum lodging rates are based upon the General Service Administration, Departments of State and Defense rates for the location and dates of stay. The maximum rate is for a single/standard sleeping room per person or single occupancy.
For lodging associated with an externally-designated conference, the maximum lodging rate does not apply if the attendee stays at the venue location. For lodging associated with a Purchase & Payment of Lodging. Additionally, faculty and staff may pre-plan their expenses using the new .
大奖娱乐官方网站主页When the University traveler is expected to incur costs for meals and incidentals for overnight business travel, the University will reimburse meal and incidental expenses (M&IE) under a per diem allowance. The maximum M&IE per diem allowance will be at the rate established by the General Service Administration, Departments of State and Defense for the location of each full day’s (24 hours) travel. The M&IE per diem allowance will only be paid when the traveler is expected to incur costs for meals and incidentals; business travel requires an overnight stay outside the traveler’s headquarters and when the travel is supported by a University business purpose.
大奖娱乐官方网站主页For Continental U.S. locations, the incidental portion of the M&IE per diem allowance is $5.00. For Non-Continental U.S. and foreign locations, the incidental portion of the M&IE per diem varies by the location.
Travel that does not include an overnight stay will be limited to a tax reportable day trip meal allowance of $15 per day when the approving authority expects the traveler to incur meal expenses. No day trip meal allowance will be paid when the traveler receives a provided meal, regardless of amount.
大奖娱乐官方网站主页For assistance with calculating maximum M&IE, please use the new . Additional information related to maximum M&IE rates is available in Travel & Expense – Meal and Incidental Expense (M&IE) Per Diem Allowance Reimbursements.
大奖娱乐官方网站主页Other expenses are permitted if they are necessary, reasonable, and allocable for the conduct of University business, such as photocopying, Internet, fax, or telephone services or charges. Keep receipts to verify charges; additional justification may be necessary for some expenses.
Personal vehicles may be used for activities on your sponsored project. Reimbursement is provided at the University’s standard mileage rate for personal vehicles (e.g., cars, trucks, vans). Business mileage will be reimbursed at the IRS authorized mileage rate in effect on the date of travel using the most direct route. For personal vehicles, this rate is $0.575/mile; for motorcycles it is $0.545/mile.
All individuals requesting mileage reimbursement must have an approved Driver Authorization Form on file with the Use of Personal Vehicles, Rental Cars and Fleet for Business Transportation.
大奖娱乐官方网站主页Rental vehicles may be used for activities on your sponsored project. Travel and Expense – Use of Personal Vehicles, Rental Cars, and Fleet for Business Transportation.
Taxi, Limousine, and Shuttle Services
Necessary, reasonable, and allocable charges for ground transportation are reimbursable. Whenever possible, use shuttle services offered by lodging facilities and/or conference sites, which are typically free. Receipts are required for all fares that exceed $25.
Additional information related to taxi, limousine, and shuttle services is available in Travel & Expense – Purchase & Payment Miscellaneous Travel Expenses.
to assist Principal Investigators with developing budget estimates for travel. Use of the Travel Calculator is highly encouraged for those Principal Investigators developing travel estimates for inclusion in federal grant and contract submissions. Under the Uniform Guidance, proposals must now include a detailed breakdown of travel costs (airfare, lodging, meals, registration/conference registration fees, taxi/shuttle services, rental cars, etc.). The Travel Calculator will provide lodging and meal estimates based on location and dates of travel.
Travel by Students, Participants, and Other Personnel
大奖娱乐官方网站主页Travel on sponsored programs is typically permitted for students, participants, and other personnel, so long as the travel is necessary, reasonable, and allocable. Travel is usually incorporated into the budget at the proposal stage and approved during the initial award negotiation phase.
The allocation of travel across cost categories may vary across grant programs. For example:
- Travel for undergraduate, graduate, or doctoral students on a research grant will likely be charged to the “Travel” budget category; however,
- Travel for undergraduate, graduate, or doctoral students on a training or education grant will likely be charged to the “Participant Support” budget category.
In these instances, charges allocated incorrectly may have an impact on other cost categories (e.g., Facilities & Administrative Costs). Consult with the Post-Award Specialist assigned to your Division/School/College to discuss modifications to travel expenses for students, participants, or other personnel.
The is a Web-based financial data reporting that provides detailed information regarding grant award budgets and expenditures.
Account balances available in WISDM are likely the best estimate of available funds; however, due to timing and other limiting factors, it is typically not the actual account balance. Certain expenditures are processed monthly: for example, charges for fringe benefits and indirect costs typically occur in the first week of the month for the preceding month. Therefore, an account balance on the first of any month will not include last month’s fringe benefit and indirect cost charges. PIs are strongly encouraged to connect periodically with the Post-Award Specialist assigned to their Division/School/College to obtain a more detailed and accurate account balance projection.
Cost Principles for Award Management
大奖娱乐官方网站主页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 (
On 26 December 2013, OMB released its final guidance on the changes to OMB Circulars A-21, A-110, and A-133. New federal awards issued after26 December 2014 will be governed by the Uniform Guidance. Continuations may or may not utilize the Uniform Guidance; seek guidance from your Post-Award Specialist on which terms and conditions govern your award.
Cost Principles for Educational Institutions (Revised 8 August 2000 and Amended 10 May 2004). This Circular has been relocated to . Most continuation awards issued under
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 . Most continuation awards issued under
Audits of States, Local Governments, and Non-Profit Organizations (Revised 27 June 2003 and 26 June 2007). Most continuation awards issued under
Provides guidance on managing and monitoring the award and administration of
Serves as the general terms and conditions for most
大奖娱乐官方网站主页Guide for administering funds from the U.S. Department of Education.