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10.
Award Terms & Conditions
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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.
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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.
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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.
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Documenting
Expenditure
Pre-approval
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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.
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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. |
Requirements
for
Prior Approvals |
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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.
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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.
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