Office of Research and Project Administration
SPONSORED PROGRAMS COMPLIANCE
Establishing the Groundrules
The University of Rochester receives funding from hundreds of different sponsors, including federal agencies, foundations and for-profit companies. Each of these has the right to establish its own terms and conditions for its awards. In addition, each individual award may include specific terms applicable to that award.
The terms of an individual award take precedence over the provisions of A-21. For example, although travel is not defined as unallowable in A-21, your particular award may designate travel, or more likely foreign travel, as unallowable. In that case, you may not charge those expenses to that project. Similar types of provisions may pertain to the acquisition of equipment.
Where required by the terms of the award, you MUST have the written approval of the sponsor's Grant or Contract Officer before charging specified expenses.
Note that normally all terms and conditions specified in an award "flow down" to any recipients of subawards. Awards may also contain requirements for advance notification of certain conditions.
For federal grants, OMB Circular A-110 requires prior approvals of changes in PI status (including reduction of effort by 25% or more) or other significant changes in scope of work.
A 1999 situation involving a PI at another academic institution illustrates the seriousness with which Federal agencies view these requirements. In that situation, a PI had failed to report a significant change is his personal situation, requiring his absence from the project. An individual in his lab reported this situation to the sponsor. (The PI had been charging 50% of his effort and salary to the project.) As a result of the "whistle blower" provisions of the Federal False Claims Act, damages were tripled and the resulting settlement cost the institution involved $920,000.
Cost-type contracts (vs. grants) have other requirements, and typically require many more approvals than grants. Required notifications must be in writing to the Contract Officer.
Finally, award notices specify requirements for reports. PIs who fail to submit timely technical or progress reports, for example, risk losing their own funding, and jeopardize the funding of other U of R PIs. Recently, University of Rochester has seen an increasing number of sponsors, both federal AND non-federal, exercising their right to suspend funding in these situations.