Every funding agency has its own requirements regarding the procedures that have to be followed for changes/modifications that result in program activities. Typically the award documents provide instructions on what you need to do for personnel changes, budget revisions, changes to program activities, no-cost extensions, and other similar issues. However, sometimes this language can be unclear or confusing. If you have questions or need assistance with any post award activities, please contact ORI.
Some modifications require approval by the funding agency. Some modifications can be approved internally (by a UTC authorized official only). However, any change/modification that is required during post-award activities must be reviewed and approved by ORI before documents can be submitted to the funding agency.
Post-Award Grant/Contract Activities handled through the Compliance Division
Typically if there are performance/technical reports required on your project, the terms and conditions of the award/contract will detail the requirements and due date. At the time of your award, the Office of Research Integrity will review the terms and conditions of your award/contract and provide you with a document detailing the requirements since often this language is unclear or confusing. If performance/technical reports are required, ORI will do its best to send you a reminder 30 days prior to the due date of the report.
Once you have completed the report, you will need to send a copy to ORI for review and approval prior to sending the report to the funding agency.
It is the principal investigator's responsibility to maintain accurate and comprehensive accounting and performance records. All records must be supported by source documentation such as cancelled checks, paid bills, purchase orders, invoices, payrolls, time and attendance records, and contract and sub-grant award documents. Carefully read your award document or contract to determine how long this documentation needs to be maintained following termination of grant activities. Please review the "Monitoring and Reporting Program Performance" document for more information.
Anytime there is a change in key personnel that results in a change of effort of 25% or more, approval is required by the funding agency. You will need to prepare a letter stating the reason for the change; describe how you can continue to effectively implement the program in the interim; and, if the change results in the employment of new personnel (not just a reduction in effort), you will need to provide information on the qualifications of the person who will fill the position, including their vitae. If the change is a reduction in effort only, which is not advised unless unforeseen problems in the program have resulted in the need for the change (e.g., a position is going down from 100% to 75%) you will need to fully explain why the change is required, how you will continue to provide the services detailed within the program narrative (how you will meet the goals and objective), and how the funding will be reallocated.
If your program should require a change in key personnel please contact the Director of Research Integrity to discuss the change. If a change is required, the letter prepared for the funding agency will need to be reviewed by ORI prior to submission.
As a general rule, a change in the budget of 10% or less (of the total budget amount) does not have to be approved by the funding agency. Please check the terms and conditions of your award/contract to be sure and if you are unclear, please contact ORI for assistance.
You will need to prepare the budget revision and send it to the office of Partnerships and Sponsored Programs (OPSP) for review. OPSP will submit the revision to the Business & Financial Affairs office on your behalf.
A budget revision of 10% or greater will have to be approved by the funding agency. You will need to prepare a revised budget and a letter of explanation detailing why the changes are required. Both documents will need to be submitted to OPSP for review and approval prior to submission to the funding agency.
Once the change has been approved by the funding agency and official approval of the change received, OPSP will submit the budget revision and approval to the Business & Financial Affairs office on your behalf.
If you find that you will not be able to complete your project within the project period you will need to request a no-cost extension. Each program has a specified time line for no-cost extensions, and it will be stated in the terms and conditions of the award/contract. Please allow for at least 90 days prior to the end date to make this determination.
The approval process varies between the funding agencies. Most federal agencies allow the institution (UTC) to approve a one-time no-cost extension for a period up to 12 months. However, some agencies require that you submit the no-cost extension request to them for approval.
If a no-cost extension is required, you will need to prepare a letter detailing the reason the extension is required and articulate the activities that will be performed during the extension period. You should ask for the full 12 months even if you think your project can be completed earlier since only ONE extension is allowed.
The regulations and requirements surrounding sponsored federal grant programs frequently change. ORI will do our best to keep up with these changes and keep you, the principal investigator, informed of your new roles and responsibilities. Following are some new regulations that you need to be aware of:
Pilot Program for Enhancement of Employee Whistleblower Protection (41 USC 4712)
Congress has enacted many whistleblower protection statutes to encourage employees to report fraud, waste, and abuse. You should be aware that the latest whistleblower protection statutes went into effect on July 1, 2013. The statute, 41 U.S.C. Section 4712, applies to all employees working for contractors, grantees, subcontractors and subgrantees on federal grants and contracts. The National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2013 (Pub. L. 112-239, enacted January 2, 2013) mandates a pilot program entitled "Pilot Program for Enhancement of Contractor Employee Whistleblower Protections". This program requires all grantees, their subgrantees and subcontractors to:
Inform their employees working on any Federal award they are subject to the whistleblower rights and remedies of the pilot program;
Inform their employees in writing of employee whistleblower protections under 41 U.S.C. Section 4712 in the predominant native language of the workforce; and,
Contractors and grantees will include such requirements in any agreement made with a subcontractor or subgrantee.
The statute (41 U.S.C. Section 4712) states that an "employees of a contractor, subcontractor, grantee [or subgrantee] may not be discharged, demoted, or otherwise discriminated against as a reprisal for "whistleblowing". In addition, whistleblower protections cannot be waived by any agreement, policy, form or condition of employment.
If there are other issues that arise that are unique to your program and that are not detailed in the award/contact, please contact ORI for assistance.