Post-Award
Research Appointments
Research Administration
Events Administration
General Links
- Harvard Analytics and Reporting Tool (HART)
- Participation Agreement
- Cost Transfer Policy
- Cost Sharing Policy
- Subrecipient Monitoring Toolkit
- Invoice Monitoring Guide: each federal subaward invoice must include the following language: “I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise. (2 CFR 200.415)”
- Closeout:Segment Closeout in GMAS: awards typically show as active in GMAS until 9 months after the final reports have been submitted. Other reasons an award may still be showing as active: account under development, notice not applied, payment not yet received, open segment revisions, outstanding reports, pending approvals (including cost sharing), pending or active subagreement, or a pending request.
- Anything routed in GMAS (both pre- and post-award) should be routed at least five (5) business days (technically 6) ahead of when you want something submitted: https://osp.finance.harvard.edu/policy-proposal-submission-deadlines-frequently-asked-questions
GENERAL TERMS AND CONDITIONS
Each award has it’s own terms and conditions which overrides the general sponsor’s rules. It’s best to start with the award agreement for specific language on any matter to confirm an answer or contact the Program Officer for guidance but below are general sponsor terms.
NASA
- NASA Grant and Cooperative Agreement Manual (GCAM) (Revised October 202$)
STScI
- STScI General Grant Provisions (December 2018)
- STGMS User Guide
EFFORT CERTIFICATION
The Federal government requires that faculty members or other knowledgeable individuals report and certify compensation and cost shared effort on federal awards. Harvard University uses the web-based system, ecrt, to report and certify effort. This happens on a quarterly basis as well as an annual basis.
TRAVEL & EQUIPMENT
- Harvard’s Sponsored Expenditures Guidelines
- Harvard’s Sponsored Travel Guidelines
- Federal Lowest Economy Airfare Travel Reimbursement Exception Form
- Fly America Travel Reimbursement Exception Form (FATREF)
- Open Skies Agreement (TO NOTE: effective 01/01/2021: the United Kingdom is no longer a part of the European Union (EU) & therefore, the Open Skies Agreement with EU countries no longer applies to the United Kingdom)
- When combining personal travel with Harvard business, how do you determine the portion that is allowable?
- B2P Sponsored Guidance (VJFs, Debarment Forms, COA, Split Codings, & Reporting)
NASA
Travel and Transportation
(a) The Fly American Act, 49 U.S.C. 1517, requires the recipient to use U.S. flag air carriers for international air transportation of personnel and property to the extent that service by those carriers is available.
(b)Department of Transportation regulations, 49 CFR 173, govern recipient shipment of hazardous materials and other items.
NASA Hubble Fellowship (NHFP)
Q: NASA Hubble/Einstein Postdoc Fellows Travel Reimbursement
The Faculty Contact must approve all travel (domestic and foreign) in advance.The budget justification should contain the following information for each domestic and foreign travel request:
- Purpose of the trip
- Destination
- Dates of travel
- Number of days on travel
- and the total cost for travel
Prior written approval must be obtained from STScI Grants Administration for all foreign travel that is not specified in the approved budget.
The approval from the Faculty Contact (or STScI if foreign and not included in the original budget) must be included as part of the Travel Reimbursement.
Q: Improvements to the NASA Hubble Fellowship Program Processes
Updated 04/17/2020
In an effort to streamline processes for the NASA Hubble Fellowship Program (NHFP), we are pleased to announce that there is now a Budget Template that includes cost categories specific to the NHFP, and a corresponding Budget Narrative Template.
Also, the request types listed below have been integrated into the Space Telescope Grants Management System (STGMS). Accordingly, the process for submission has changed (see below). Instructions are included in the attached STGMS Quick Reference Guide for the NHFP. This information can also be found on the NHFP Grants Resources webpage.
http://www.stsci.edu/scientific-community/grants-administration/nhfp-grant-resources
- Computing Device Request – requests must be submitted through STGMS
- Foreign Travel Request – requests must be submitted through STGMS
- Early Resignation – official notification must be submitted as a Special Request in STGMS
As with all actions performed in STGMS, the budget and requests are privilege-based. Fellows are not authorized users in STGMS and must work with their Faculty Contact or designated personnel at their Host institution to submit a report/request on their behalf.All faculty contacts have been assigned the necessary privileges. If administrative staff require the privilege(s) to perform one of the above-mentioned tasks, please reach out to Ms. Shantavia Sturgis at gms_mail@stsci.edu.
NSF
(iv) Travel (Line E on the Proposal Budget)
(a) General
When anticipated, travel and its relation to the proposed activities must be specified, itemized and justified by destination and cost. Funds may be requested for field work, attendance at meetings and conferences, and other travel associated with the proposed work, including subsistence. In order to qualify for support, however, attendance at meetings or conferences must be necessary to accomplish proposal objectives or disseminate research results. Travel support for dependents of key project personnel may be requested only when the travel is for a duration of six months or more either by inclusion in the approved budget or with the prior written approval of the cognizant NSF Grants Officer. Temporary dependent care costs above and beyond regular dependent care that directly result from travel to conferences are allowable costs provided that the conditions established in 2 CFR § 200.474 are met
Allowance for air travel normally will not exceed the cost of round-trip, economy airfares. Persons traveling under NSF grants must travel by U.S.-Flag Air carriers, if available.
(b) Domestic Travel
Domestic travel includes travel within and between the U.S., its territories and possessions.18 Travel, meal and hotel expenses of grantee employees who are not on travel status are unallowable. Costs of employees on travel status are limited to those specifically authorized by 2 CFR § 200.474.
(c) Foreign Travel
Travel outside the areas specified above is considered foreign travel. When anticipated, the proposer must enter the names of countries and dates of visit on the proposal budget, if known.
STScI
Equipment not included in the Approved Budget
E. Equipment Equipment is defined as a per-unit acquisition cost of $5,000 or more with a useful life of more than one year.
- The purchase of equipment including computer or related hardware is allowable if it was included in the approved budget. Prior STScI approval is required to purchase equipment that was not specifically authorized in the approved budget.
- The purchase of equipment is generally not approved for private or for-profit organizations.
- Property records must be maintained that include a description of the equipment, a serial number or other identification number, the source of funding for the equipment, the cost of the equipment, and the date of purchase.
- A list of all equipment purchased on the grant must be submitted at the end of the grant period (Ref. Section 24, Reporting Requirements). If no equipment was purchased on the grant, a negative report is required.
- Unless otherwise stated in the Grant Award/Amendment Documents, title to and responsibility for all equipment purchased with grant funds is vested in the Grantee Institution provided that:
- The Grantee uses the equipment for the authorized activities of the grant, and
- When no longer needed for the original grant, the equipment is used for other grants funded by STScI or activities under federal awards from other federal awarding agencies.
- It is the responsibility of the Grantee and the Grantee Institution to ensure that no equipment or supplies (i.e. laptops, notepads, etc.) are transferred to a non-U.S. Institution or a non-U.S. investigator during or after the period of performance.
STScI Sponsored Travel Update: December 2018
NASA requires that grantees are in strict adherence with travel on U.S. Flag Carriers. Open Skies Agreement is not a provision that flows down to STScI. A U.S. flag air carrier must be used for all legs of the route on which a U.S. flag air carrier is an option. If a U.S. flag air carrier does not travel to the final destination or does not provide service on a portion of the route, the traveler may use a foreign air carrier only on the leg(s) for which U.S. service is unavailable. The traveler(s) is required to inform STScI in advance if a U.S. flag air carrier does not travel to the final destination or does not provide service on a portion of the route. The traveler(s) will need to include the email documentation with his/her travel reimbursement.
Travel within the United States and its territories considered domestic travel. All other locations are considered foreign. Air travel, domestic or foreign, for personnel and property, must be aboard a U.S. flag carrier. Airfare costs in excess of the customary standard commercial airfare (coach or equivalent), federal government contract airfare (where authorized and available) or the lowest commercial discount airfare are unallowable except when such accommodations would:
a. Require circuitous routing;
b. Require travel during unreasonable hours;
c. Excessively prolonged travel; or
d. Result in additional costs that would offset the transportation savings.
The example in question is a ticket to Germany that was booked on United Airlines, operated by Lufthansa. The Flight number is UAXXXX (not LHXXXX). Is this allowable given that there are few to no American carriers that fly to Germany?
Yes, it is allowable to purchase a ticket through United Airlines for a flight operated by Lufthansa.
An example of the code-share that are in compliance and not in compliance:
The traveler is considered to be on a code-share flight if he/she purchases a ticket from one carrier but flies on an aircraft owned by another airline. This would be a ticket that is issued by a U.S. air carrier that states “U.S. air carrier flight XXXX operated by foreign air carrier.” There may be a list of code-share partners on the U.S. air carrier’s website; however, not all flights on those partner airlines are operated under code-share agreements. Only code-share flights booked properly through the U.S. carrier are allowable.
Allowable: AA 1234 operated by QF 4321
Unallowable: QF 4321 operated by AA 1234
(AA = American Airlines, QF = Qantas Airways)
Reporting Templates & Deadlines
NASA
Annual Technical Report: A Progress Report describing accomplishments during the reporting period is due annually 60 days before the anniversary date of the grant, except for the final year.
Content of Annual Progress Reports include:
- Changes in originally approved scope of work for the coming year,
- Updates to management plans,
- Interim New Technology Summary Report (as applicable),
- Any publication of peer-reviewed articles,
- Any publication of data sets or other products (including code), and
- Any other elements needed or requested by NASA staff to determine progress on the project.
Final Reports:
Summary of Research (or Educational Activity Report) is due within 90 days after the expiration date of the grant, regardless of whether or not support is continued under another grant.
A Final Inventory Report of Federally Owned Property, including equipment where title was taken by the Government, must be submitted no later than 60 days after the expiration date of the grant. Even if there is no reportable equipment, Final Inventory Reports are required. Summary of Research Form
NSF
Annual Project Reports: submitted electronically no later than 90 days prior to the end of the current budget period. The report is considered due during that 90 day period. The report becomes overdue the day after the 90 day period ends. Annual project reports may not be required for fellowship awards.
Final Project Report: not cumulative; it is the last annual report of the project and should be written specifically for the most recently completed budget period. Final project report should be submitted electronically no later than 120 days following the end of the grant. Final project reports may not be required for institutional graduate research fellowships.
NSF Annual Report – to be filled out via Research.gov – should not be uploaded as a PDF
STScI
Updated as of December 2018
Annual Technical Report:
- Brief comparison of actual accomplishments with the goals and objectives for the period, the findings of the investigator, or both. Reason why established goals were not met, if appropriate. Typically due 30 days after the anniversary date of the grant (except in final year).
Final Reports:
- Final Performance Report: Brief comparison of actual accomplishments with the goals and objectives for the period, the findings of the investigator, or both. Reason why established goals were not met, if appropriate. Due within 90 days of the grant end date.
- Final Equipment Report: List of equipment and cost. Due within 90 days of grant end date. Negative report is required.
- New Technology Report: The development of new technology resulting from the research. Due within 90 days of grant end date. Negative report is required.
Prior Approval & Other Requests
During the life of a grant project, it is likely that modifications to the award will be needed that deviate from the submitted proposal. Many of these changes require prior approval from the sponsor before Harvard can process the change. For more information on prior approvals from the most common federal sponsors, please refer to the NSF Research Terms & Conditions (Research Terms and Conditions Appendix A – Prior Approval Matrix).
Requests for modifications that require sponsor approval also require that a GMAS request be entered. The most common requests types are:
- No Cost Extensions
- Changes to Key Personnel
- Changes to Effort
- Re-budgets
- PI Changes or Leaves of Absence
- Addition of subagreements (foreign or domestic)
- Early Termination
- Carry-forward
- Pre-Award Expenditures
Examples of circumstances requiring prior approval from a sponsor, and therefore a GMAS request include, but are not limited to:
- Changes in the scope or the objective of the project
- Changes in the Principal Investigator or Key Personnel
- Absence for more than three (3) months, or a 25% reduction in the time devoted to the project by the Principal Investigator or Key Personnel
- Transfers of funds allocated for training expenses (direct trainee payments, stipends, tuition, fees) to other budget categories
- Subcontracting a substantive programmatic portion of the work, which results in a change in scope, unless described in the application and funded in the approved award
- Subcontracting with a foreign entity
- Equipment not approved in the original award with a cost above $25,000 constitutes a change in the scope of work, mandating approval
Research.gov (NSF) screenshot of options for New Notification/Requests
No Cost Extensions (NCE)
No Cost Extension Requests are routed in GMAS – these should be routed at least five business days ahead of the deadline to allow OSP time to review & submit.
NASA
National Aeronautics and Space Administration
The recipient may make a one-time no-cost extension, not to exceed 12 months, prior to the established expiration date. Written notification of such an extension, with the supporting reasons and the progress report, must be received by the NASA Grant Officer at least ten days but no sooner than 60 days prior to the last day of the period of performance.
OSP will submit the request via the NASA Shared Services Center. The notification pieces (justification plus progress report) are routed in GMAS as a NCE request.
NSF
National Science Foundation (NSF) updated as of 2023 [page VI-2]
Grantee-Approved Extension (first 12 month extension): provide sponsor with supporting reasons for the extension and the revised end date at least ten calendar days prior to the current end date.
NSF-Approved Extension (anything after the first 12 month extension): must explain the need for the extension and include an estimate of the unobligated funds remaining and the plan for their use. This request is submitted by OSP via Research.gov and is due at least 45 days prior to the current end date.
The request is created in Research.gov, released to AOR, then upload the documentation into GMAS as NCE Request. If NCE is approved, the annual progress report will be due so it’s best to ask for the progress report at the time of the NCE submission.
STScI
Space Telescope Science Institute (STScI) updated as of December 2018
STScI expects that the Principal Investigator and grant personnel will complete the objectives of the proposed grant within the period of performance. If the work is not completed within that period, a one-time-only request for a no-cost extension of the period of performance may be requested at least 30 days prior to the end date of the award. No further requests will be accepted. Requests received after the end date of the award may be denied.
A. The request must include (filled out in STGMS):
- A technical or scientific reason the extension is necessary;
- A summary of the progress to date. The information can be provided in the request or in a separate Interim Performance Report;
- A description of the work to be performed during the extension period; and
- A description of how the funds will be spent during the extension period.
B. All no-cost extension requests are subject to the approval of STScI and will be denied if:
- It is merely for the purpose of using unobligated balances;
- The extension requires additional funds;
- STScI determines that the extension involves any change in the approved objectives or scope of work;
- The grantee is not in compliance with all of the reporting requirements (i.e. overdue interim financial or performance reports); or
- The terms and conditions of the grant award or a subsequent amendment to the grant prohibit an extension.
C. All expenditures incurred during the extended period of performance must be directly related to the scope of work as described in the approved proposal.
Changes to Key Personnel/Changes to Effort
NASA
D7. Change in Principal Investigator or Scope
(a) The recipient shall obtain the approval of the NASA Grant Officer for a change of the Principal Investigator, or for a significant absence of the Principal Investigator from the project, defined as a three-month absence from the program or a 25 percent reduction in time devoted to the project. Significantly, reduced availability of the services of the Principal Investigator(s) named in the award instrument could be grounds for termination, unless alternative arrangements are made and approved in writing by the Grant Officer.
(b) Prior written approval is required from NASA if there is to be a significant change in the objective or scope of the project.
7.9 Change of Principal Investigator or Recipient Institution
1. When a principal investigator changes organizational affiliation, the current recipient institution is given an opportunity to find a replacement. The final decision on whether an acceptable replacement is available, or that the research effort should follow the original principal investigator to the new location, is at the discretion of the NASA Technical Officer. Grant Officers should process a potential change of principal investigator as follows:
a. If the decision is made that the grant will not follow the PI to the new institution, and the current institution does not recommend a substitute for NASA approval, the grant with the current institution is ended by mutual consent or, if necessary, unilaterally by the Grant Officer.
b. If the decision is made that the grant will not follow the PI to the new institution, and the current recipient institution does recommend for NASA approval a new PI, the Grant Officer will seek concurrence/nonconcurrence from the Technical Officer. The current recipient shall provide a PI curriculum vitae and any other documentation that might aid in the evaluation of the new PI submission by NASA. Upon Technical Officer concurrence of the recommendation, the Grant Officer may initiate a supplement to change the PI. If the Technical Officer does not concur with a recommended new PI and the grant will not follow the PI to the new institution, then the grant with the current institution may be ended by mutual consent or, if necessary, unilaterally by the Grant Officer.
c. If the decision is made that the research activity will follow the PI to the new institution and the funds on the grant are still available, the grant with the current institution may be ended and a replacement grant issued to the new institution. When the termination/new award process is used, a fully endorsed proposal for a replacement grant will be requested from the PI’s new institution to continue the research. Although such a proposal will be reviewed in the normal manner, every effort will be made to expedite a decision. Regardless of the action taken on the new proposal, final reports on the original grant, describing the scientific progress and expenditure to date will be required.
- When transferring research activities, the Grant Officer, with concurrence from the award’s Technical Officer, performs steps for a new award, such as determination of appropriate funding for the original institution, receiving in writing the intent of the original institution to relinquish the grant, de-obligating any remaining funds from the original grant with the original institution, ensuring sufficient 53 funds are available for the new institution’s proposal, and updating records or files.
- Following a review and evaluation of the proposal from the new institution by the program office, if the proposal is accepted, the Technical Officer will forward a recommendation to the Grant Officer to award to the new institution.
d. If the current institution recommends that both the PI and institution be changed, then a new award must be issued per paragraph C above.
2. The evaluation and recommendation from the Technical Officer for the transfer of the research activity to the new institution must include:
a. Verification that the PI changing institutions still has the prerequisite scientific and/or technical expertise, and knowledge of the research activity (as supported by the basis for the original award to the PI’s old institution);
b. Verification that the new institution has the necessary facilities and support to continue the original research;
c. Statement from the Technical Officer verifying that NASA is satisfied with the scientific and/or technical progress of the current PI;
d. Statement, with supporting rationale, that it will not be cost effective nor time efficient to recompete the effort, and that it is not likely NASA will realize any benefit by recompeting the research activity; and
e. Identification of the suggested amount of unexpended research funding to be transferred from the initial recipient institution to the PI’s new institution.
Grants involving a transfer to another institution do not need to be re-advertised and there is no requirement to perform a market research analysis or market survey. After receiving approval of the new institution’s proposal from the Technical Officer and coordinating with the Center Chief Financial Officer (CFO) on the intended new award to include verification that sufficient funds are available, the contracting or Grant Officer may make the award to the new institution.
NSF
Source: NSF PAPPG 20-1
b. Changes in Person-Months Devoted to the Project
If the PI/PD or co-PI/co-PD will devote substantially less time to the project than anticipated in the approved proposal, (defined in the applicable grant terms and conditions as a reduction of 25% or more in time) he/she should consult with the appropriate officials of the grantee organization. Requests for changes to the personmonths devoted to the project must be signed and submitted by the AOR via use of NSF’s electronic systems. This request must be submitted at least 30 days before the proposed change, or as soon as practicable after the prospective change is known. If the grantee organization or NSF determines that the reduction of effort will substantially impair the successful execution of the project, the NSF Program Officer will consult the NSF Grants Officer. The NSF Grants Officer may:
(i) request the grantee to nominate a replacement PI/PD or co-PI/co-PD acceptable to the cognizant NSF Program Officer;
(ii) initiate the termination procedures described in Chapter XII.A.; or
(iii) negotiate an appropriate modification to the grant.
STScI
Source: STScI GGP December 2018
Section 19 – Personnel Changes
A. Prior approval from STScI is required for all changes to key grant personnel:
- Scientific or Administrative Principal Investigator (PI) of a program or grant.
- Scientific or Administrative PI’s level of effort in grant activities.
- PI absence from the grantee institution for more than 30 days.
- STScI may require the grantee Institution to designate an Administrative PI to assume responsibility for the grant for the duration of the PI’s absence.
- Personnel that transfer to a foreign institution are no longer eligible to receive support from STScI grants in any way. Charges incurred after the effective date of transfer from the grantee institution are unallowable.
- Co-I added to the Program.
Changes to scientific personnel also require approval of the STScI Head of Science Policies Division. Contact Grants Administration to coordinate this action.
B. Submit notifications and requests for approval via STGMS or email (gms_mail@stsci.edu) at least 30 days prior to the change, or as soon as the Investigator or Institution has knowledge that a change will occur. STScI will issue a Grant Amendment that documents the approved changes.
C. If arrangements proposed by the grantee are not acceptable to STScI, the grant may be suspended or terminated and STScI will provide closeout instructions.
It is the responsibility of all investigators to maintain current addresses and affiliation information in MyST: https://profile.stsci.edu
Re-budgets
For federal most awards, the Uniform Guidance grants permission to an awardee to re-budget, except when there is a change in the SOW or the need for additional funding
NSF
Source: NSF PAPPG 20-1
3. Prior Written Approvals
The funding of items identified in the NSF grant budget constitutes NSF’s authorization for the grantee to incur these costs, provided there is not a specific limitation in the grant language and the costs are otherwise allowable, allocable, and reasonable in accordance with the cost principles contained in 2 CFR § 200, Subpart E.
If required in furtherance of the project, the grantee is authorized to transfer funds from one budget category to another for allowable expenditures. Grantees should refer to the applicable grant general terms and conditions referenced in the grant. The Research Terms and Conditions (RTC), Appendix A, (NSF column) provides a consolidated listing of prior approvals that are required to be obtained from NSF. Unless otherwise specified in the grant notice or the applicable grant general terms and conditions, no additional prior approvals beyond those specified in RTC Appendix A are required. Chapter VII.A.2 also provides a listing of required notifications to NSF.
When a change requires NSF approval, the request must be submitted via NSF’s electronic systems. The request should clearly state which budget items, if any, are to be changed and by what amounts, and should explain the reasons for any changes.
Research.gov has the following options for Types of Change(s) for Budget Activities:
- Change in Person-Months Devoted to the Project
- Pre-award Costs in Excess of 90 Days
- Reallocation of Funds Provided for Participant Support Costs
- Rearrangement/Reconversion costs in excess of $25,000 (re: Construction/Facility Improvement Costs)
- Salaries of Administrative or Clerical Staff
- Travel Costs for Dependents
- Additional categories of participant support costs other than those described in 2 CFR § 200.75
Process:
- The request is entered into Research.gov as a Reallocation of Funds
- Enter the amount that the restricted category (i.e. Participant Support Costs) is being adjusted to
- Enter the Justification for the Reallocation of Funds – must include why the funds are no longer needed for that designated category
- Must also include the figure of how much is moving from the Restricted Category into the New Categories in terms of the NSF Template Budget (i.e. Moving $X from G.2. Participant Support Travel – $X going to E.2 Domestic Travel and $X going to I. Indirect Costs)
- Download a PDF copy of that page from Research.gov and Release to Org
- Create a Request to Reallocate Funds from Restricted Categories in GMAS
- Upload the PDF copy above
- Upload the Revised Excel Budget
- Upload a Revised Budget Justification
- Route to PI (autopopulated), OSP (autopopulated), Department Approver (Theresa Ross – manually added), and Dean/Designee Signature (Jennifer Lech – manually added)
- Mention in routing notes: Meets RAS Review Critieria as IDC amount is being adjusted
- All parties review, sign off in GMAS, and OSP then submits in Research.gov
STScI
Source: STScI GGP 2018
Section 18 – Revisions to Budgets or Program
A. STScI grants are awarded based on an approved proposal and budget. The budget is a detailed financial expression of the project or program and shall be related to performance for the purpose of program evaluations whenever appropriate. Prior approval from STScI is required when there are deviations from the approved budget and program plans that will:
1. Result in changes to the scope or the objectives of the grant (even if there is no associated budget revision with the changes, prior written approval from STScI is required);
2. Result in items being added to the budget which require prior approval from STScI (i.e. equipment purchases) that were not specifically authorized in the Grant Award or Amendment Documents;
3. Result in transferring substantive project activities to a third party by sub-granting, contracting, or other means;
4. Involve the transfer of funds between direct cost categories, or the transfer of funds between direct and indirect cost categories when the cumulative amount of such transfers is expected to exceed $25,000 or 25% of the total grant approved by STScI, whichever is less.
B. All other budget changes do not require STScI approval.
C. Revised budgets must be submitted to STScI for any revisions that exceed the amounts indicated above. D. Revisions must be submitted via STGMS and include a revised budget narrative.
PI Changes or Leaves of Absence
NASA
D7. Change in Principal Investigator or Scope
(a) The recipient shall obtain the approval of the NASA Grant Officer for a change of the Principal Investigator, or for a significant absence of the Principal Investigator from the project, defined as a three-month absence from the program or a 25 percent reduction in time devoted to the project. Significantly, reduced availability of the services of the Principal Investigator(s) named in the award instrument could be grounds for termination, unless alternative arrangements are made and approved in writing by the Grant Officer.
(b) Prior written approval is required from NASA if there is to be a significant change in the objective or scope of the project.
7.9 Change of Principal Investigator or Recipient Institution
1. When a principal investigator changes organizational affiliation, the current recipient institution is given an opportunity to find a replacement. The final decision on whether an acceptable replacement is available, or that the research effort should follow the original principal investigator to the new location, is at the discretion of the NASA Technical Officer. Grant Officers should process a potential change of principal investigator as follows:
a. If the decision is made that the grant will not follow the PI to the new institution, and the current institution does not recommend a substitute for NASA approval, the grant with the current institution is ended by mutual consent or, if necessary, unilaterally by the Grant Officer.
b. If the decision is made that the grant will not follow the PI to the new institution, and the current recipient institution does recommend for NASA approval a new PI, the Grant Officer will seek concurrence/nonconcurrence from the Technical Officer. The current recipient shall provide a PI curriculum vitae and any other documentation that might aid in the evaluation of the new PI submission by NASA. Upon Technical Officer concurrence of the recommendation, the Grant Officer may initiate a supplement to change the PI. If the Technical Officer does not concur with a recommended new PI and the grant will not follow the PI to the new institution, then the grant with the current institution may be ended by mutual consent or, if necessary, unilaterally by the Grant Officer.
c. If the decision is made that the research activity will follow the PI to the new institution and the funds on the grant are still available, the grant with the current institution may be ended and a replacement grant issued to the new institution. When the termination/new award process is used, a fully endorsed proposal for a replacement grant will be requested from the PI’s new institution to continue the research. Although such a proposal will be reviewed in the normal manner, every effort will be made to expedite a decision. Regardless of the action taken on the new proposal, final reports on the original grant, describing the scientific progress and expenditure to date will be required.
- When transferring research activities, the Grant Officer, with concurrence from the award’s Technical Officer, performs steps for a new award, such as determination of appropriate funding for the original institution, receiving in writing the intent of the original institution to relinquish the grant, de-obligating any remaining funds from the original grant with the original institution, ensuring sufficient 53 funds are available for the new institution’s proposal, and updating records or files.
- Following a review and evaluation of the proposal from the new institution by the program office, if the proposal is accepted, the Technical Officer will forward a recommendation to the Grant Officer to award to the new institution.
d. If the current institution recommends that both the PI and institution be changed, then a new award must be issued per paragraph C above.
2. The evaluation and recommendation from the Technical Officer for the transfer of the research activity to the new institution must include:
a. Verification that the PI changing institutions still has the prerequisite scientific and/or technical expertise, and knowledge of the research activity (as supported by the basis for the original award to the PI’s old institution);
b. Verification that the new institution has the necessary facilities and support to continue the original research;
c. Statement from the Technical Officer verifying that NASA is satisfied with the scientific and/or technical progress of the current PI;
d. Statement, with supporting rationale, that it will not be cost effective nor time efficient to recompete the effort, and that it is not likely NASA will realize any benefit by recompeting the research activity; and
e. Identification of the suggested amount of unexpended research funding to be transferred from the initial recipient institution to the PI’s new institution.
Grants involving a transfer to another institution do not need to be re-advertised and there is no requirement to perform a market research analysis or market survey. After receiving approval of the new institution’s proposal from the Technical Officer and coordinating with the Center Chief Financial Officer (CFO) on the intended new award to include verification that sufficient funds are available, the contracting or Grant Officer may make the award to the new institution.
NSF
2. Changes in PI/PD, co-PI/co-PD or Person-Months Devoted to the Project at the Initiation of the Grantee Organization
The NSF decision to support a proposed project is based to a considerable extent upon its evaluation of the proposed PI/PD and any identified co-PI/co-PD’s knowledge of the field of study and his/her capabilities to conduct the project in an efficient and productive manner. This is reflected in the NSF merit review criteria (see Chapter III). The named PI/PD (and co-PI/co-PD) should be continuously responsible for the conduct of the project and be closely involved with the effort. If the grantee determines that there is a need for the addition of a new co-PI/co-PD, or the current PI/PD or coPI/co-PD plans to, or becomes aware that he/she will: (i) devote substantially less effort to the project than anticipated in the approved proposal; (ii) sever his/her connection with the grantee organization; or (iii) otherwise relinquish active direction of the project, he/she shall advise the appropriate official at the grantee organization, who shall initiate action appropriate to the situation under the guidelines that follow.
a. Long-Term Disengagement of PI/PD or co-PI/co-PD
(i) In the event the PI/PD or co-PI/co-PD will be disengaged from the project for a period greater than three months (e.g. sabbatical leave) but intends to return, arrangements for oversight of the project must be signed and submitted by the AOR via use of NSF’s electronic systems. This request must be submitted at least 30 days before departure or as soon as practicable after the prospective disengagement is known.52 The cognizant NSF Program Officer will provide written approval to the grantee if the arrangements are satisfactory, but no formal amendment to the grant will be made. If the arrangements are not satisfactory to NSF, the grant may be terminated as prescribed in Chapter XII.A.
(ii) In the event the PI/PD or co-PI/co-PD will temporarily be working for NSF as an IPA (Intergovernmental Personnel Act employee) or VSEE (Visiting Scientist, Engineer or Educator), the appropriate officials at the grantee organization must contact the cognizant NSF Program Officer for procedural guidance regarding any existing grants or pending proposals of the PI/PD or co-PI/PD.
b. Changes in Person-Months Devoted to the Project
If the PI/PD or co-PI/co-PD will devote substantially less time to the project than anticipated in the approved proposal, (defined in the applicable grant terms and conditions as a reduction of 25% or more in time) he/she should consult with the appropriate officials of the grantee organization. Requests for changes to the personmonths devoted to the project must be signed and submitted by the AOR via use of NSF’s electronic systems. This request must be submitted at least 30 days before the proposed change, or as soon as practicable after the prospective change is known. If the grantee organization or NSF determines that the reduction of effort will substantially impair the successful execution of the project, the NSF Program Officer will consult the NSF Grants Officer. The NSF Grants Officer may:
(i) request the grantee to nominate a replacement PI/PD or co-PI/co-PD acceptable to the cognizant NSF Program Officer;
(ii) initiate the termination procedures described in Chapter XII.A.; or
(iii) negotiate an appropriate modification to the grant.
c. Addition of co-PI/co-PD
In the event the grantee desires to add a new co-PI/co-PD to a project, the AOR must sign and submit the request via use of NSF’s electronic systems. The new co-PI/co-PD’s name, biographical sketch, current and pending support from all ongoing projects and proposals, as well as a justification for the addition must also be included in the request. The contact information for the new co-PI/co-PD also should be included. If approved by NSF, the Grants Officer will amend the grant.
d. Withdrawal of PI/PD or co-PI/co-PD
In the event the PI/PD or co-PI/co-PD severs his/her connection with the grantee organization or otherwise relinquishes active direction of the project, the AOR must sign and submit a notification of the withdrawal of the PI/PD or co-PI/co-PD via use of NSF’s electronic systems. This request must be submitted at least 30 days before the proposed change, or as soon as practicable after the prospective withdrawal is known. The grantee also must:
(i) initiate transfer of the grant as described in Chapter VII.B.2.f;
(ii) nominate a substitute as described in Chapter VII.B.2.e; or
(iii) initiate grant closeout procedures through submission of final reports as described in Chapter VII.D.2.
e. Substitute (Change) PI/PD or co-PI/co-PD
In the event the grantee desires to continue the project with a substitute PI/PD or co-PI/co-PD, the AOR must sign and submit the request via use of NSF’s electronic systems. The substitute PI/PD’s name or co-PI/PD’s name, biographical sketch, current and pending support from all ongoing projects and proposals, as well as a justification for the substitution must also be included in the request. The contact information for the substitute PI/PD or coPI/co-PD also should be included. If approved by NSF, the Grants Officer will amend the grant. If not approved, NSF may take steps, pursuant to Chapter XII.A to suspend or terminate the grant.
In cases where a former NSF employee or IPA is being reappointed as PI or co-PI to an award they were previously involved with, the grantee must submit a “Change of PI” request using the Research.gov Notifications and Requests module. The change in PI request should include documentation from the AOR designating a substitute negotiator for that award under the Associated Documents section. A co-PI request should designate the PI as the substitute negotiator.
f. Disposition of a Grant When a PI/PD Transfers from One Organization to Another Organization
(i) Policy. When a PI/PD plans to leave an organization during the course of a grant, the organization has the prerogative to nominate a substitute PI/PD or request that the grant be terminated and closed out. In those cases where the PI/PD’s original and new organizations agree, NSF will facilitate a transfer of the grant and the assignment of remaining unobligated funds to the PI/PD’s new organization. This should normally be done with a tripartite agreement (involving NSF, the PI/PD’s original organization and new organization), or by a subaward arrangement between the PI/PD’s original and new organizations, subject to NSF’s consent. (See Chapter VII.B.3)
(ii) Procedures. When a PI/PD plans to leave an organization during the course of a grant, the PI/PD or the SPO, shall notify the cognizant NSF Program Officer. If the project is to continue with the original organization, the cognizant NSF Program Officer should advise the grantee to nominate a substitute PI/PD (see Chapter VII.B.2.e). If the project is to be continued at the PI/PD’s new organization, and if NSF and both organizations agree, formal notification of the impending transfer can be electronically initiated by either the PI/PD or the PI/PD’s organization. The amount transferred has to be equal to or less than the unobligated balance. The request shall include a:
(a) brief summary of progress to date;
(b) description of work yet to be accomplished;
(c) completed on-line transfer request, including total disbursements and unpaid obligations to date (transfer amount will be automatically calculated, based on the amount entered in total disbursements). The original organization is responsible for including in the total estimated disbursements, any anticipated costs yet to be incurred against the original grant;
(d) detailed line item budget for the transfer amount and any outstanding continuing grant increments; and
(e) If funding is requested to support a postdoctoral researcher, then the request must include the requisite mentoring plan as described in Chapter II.C.2.j. The plan must be uploaded under “Mentoring Plan” in the Supplementary Documentation section of Research.gov. The PI must report on the mentoring activities provided to the individual(s) in annual and final project reports.
The original organization concurs with the transfer of the award by electronically forwarding the request to the new organization.
The new organization completes the request by providing a detailed budget for the transfer amount agreed to by both organizations. The AOR of the new organization must sign and submit the request via use of NSF’s electronic systems. Submission of the request constitutes agreement by the new organization to assume responsibility for completion of the project effort and to administer the grant (as originally awarded) from the transfer date to completion in accordance with any special terms and conditions and the applicable general terms and conditions that normally govern NSF grants made to the new organization. Special terms and conditions, as appropriate, cited in the original award will convey to the new grantee organization.
NSF will assign a proposal number at the time of submission. This proposal number will become the new grant number when the transfer is approved by an NSF Grants Officer.
(iii) Fund Transfer. Upon receipt of the above material, NSF will review the request and, if approved, deduct the specified transfer amount from the original grant and re-establish it under a new grant number at the new organization. Award notification by the NSF Grants Officer will constitute NSF approval of the grant transfer. The award notification also will specify the applicable general terms and conditions that govern the grant.
(iv) Monetary Discrepancies. Upon transfer of the grant to the new organization, any monetary discrepancies must be resolved between the original and the new grantee. NSF will not intervene in any disputes between the two organizations regarding the transferred amount.
(v) Equipment Transfers. Equipment purchased with NSF funds for use in a specific project should remain available for use for the duration of the project. PI/PDs who are in the midst of projects that included funding for equipment and who will continue the project at a new organization with NSF support, should arrange with their original organization to have the equipment transferred with them. Shipping costs for such equipment may be charged to the original or transferred grant as an allowable cost. Budgets should not include funds to “buy” equipment that had been previously obtained with Federal funds. (vi) Possible Alternatives to the Transfer Process. When the amount of time and funds remaining in a project are modest, and if both the original and new organizations are in agreement, the original organization may issue a subaward to the new organization for completion of the project. This and other possible alternatives should be discussed with the NSF Grants Officer.
STScI
Source: STScI GGP December 2018
Section 19 – Personnel Changes
A. Prior approval from STScI is required for all changes to key grant personnel:
- Scientific or Administrative Principal Investigator (PI) of a program or grant.
- Scientific or Administrative PI’s level of effort in grant activities.
- PI absence from the grantee institution for more than 30 days.
- STScI may require the grantee Institution to designate an Administrative PI to assume responsibility for the grant for the duration of the PI’s absence.
- Personnel that transfer to a foreign institution are no longer eligible to receive support from STScI grants in any way. Charges incurred after the effective date of transfer from the grantee institution are unallowable.
- Co-I added to the Program.
Changes to scientific personnel also require approval of the STScI Head of Science Policies Division. Contact Grants Administration to coordinate this action.
B. Submit notifications and requests for approval via STGMS or email (gms_mail@stsci.edu) at least 30 days prior to the change, or as soon as the Investigator or Institution has knowledge that a change will occur. STScI will issue a Grant Amendment that documents the approved changes.
C. If arrangements proposed by the grantee are not acceptable to STScI, the grant may be suspended or terminated and STScI will provide closeout instructions.
It is the responsibility of all investigators to maintain current addresses and affiliation information in MyST: https://profile.stsci.edu
Addition of Subagreements (foreign or domestic)
NSF
4. Subawarding or Transferring Part of an NSF Award (Subaward)
Excluding the purchase of items such as commercially available materials and supplies, equipment or general support services allowable under the grant, no part of an NSF award may be subawarded or transferred to another organization without prior NSF authorization. The intent to enter into such arrangements should be disclosed in the proposal. If it becomes necessary to subaward or transfer part of an NSF award after a grant has been made, the grantee shall submit, at a minimum:
a. a clear description of the work to be performed by each subrecipient;
b. a separate budget and budget justification for each subaward; and
c. If funding is requested to support a postdoctoral researcher, and the original proposal did not include a mentoring plan, then the request must include the requisite mentoring plan as described in Chapter II.C.2.j. The plan must be uploaded under “Mentoring Plan” in the Supplementary Documentation section of Research.gov.
The request must be signed and submitted by the AOR via use of NSF’s electronic systems, and NSF authorization will be indicated by an amendment to the grant signed by the Grants Officer. The NSF grant terms and conditions will identify which articles flow-down to subrecipients.
Procurements under NSF grants are subject to Chapter X.C as well as 2 CFR § 200.317-326
STScI
Source: STScI GGP 2018
Section 18 – Revisions to Budgets or Program
A. STScI grants are awarded based on an approved proposal and budget. The budget is a detailed financial expression of the project or program and shall be related to performance for the purpose of program evaluations whenever appropriate. Prior approval from STScI is required when there are deviations from the approved budget and program plans that will:
1. Result in changes to the scope or the objectives of the grant (even if there is no associated budget revision with the changes, prior written approval from STScI is required);
2. Result in items being added to the budget which require prior approval from STScI (i.e. equipment purchases) that were not specifically authorized in the Grant Award or Amendment Documents;
3. Result in transferring substantive project activities to a third party by sub-granting, contracting, or other means;
4. Involve the transfer of funds between direct cost categories, or the transfer of funds between direct and indirect cost categories when the cumulative amount of such transfers is expected to exceed $25,000 or 25% of the total grant approved by STScI, whichever is less.
B. All other budget changes do not require STScI approval.
C. Revised budgets must be submitted to STScI for any revisions that exceed the amounts indicated above. D. Revisions must be submitted via STGMS and include a revised budget narrative.
Early Termination
NASA
7.14 Award Termination
Per 2 CFR 200.340, Termination, NASA or a pass-through entity may terminate an award in whole or in part as follows:
- By NASA or a pass-through entity if a recipient fails to comply with the terms and conditions of an award.
- By NASA or a pass-through entity, to the greatest extent authorized by law, if an award no longer effectuates the program goals or agency priorities.
- By NASA or a pass-through entity with the consent of the award recipient, in which case the two parties must agree upon the termination conditions, including the effective date and, in the case of partial termination, the portion to be terminated; or
- By the recipient upon sending to NASA or a pass-through entity written notification setting forth the reasons for such termination, the effective date, and, in the case of partial termination, the portion to be terminated. However, if NASA or a pass-through entity determines in the case of partial termination that the reduced or modified portion of the award or subaward will not accomplish the purposes for which the award was made, NASA or a pass-through entity may terminate the award in its entirety; or.
- By NASA or a pass-through entity pursuant to termination provisions included in the award.
When NASA terminates an award prior to the end of the period of performance due to the recipient’s material failure to comply with the award’s terms and conditions, the cognizant NASA Grant Officer must report the termination in FAPIIS, in accordance with requirements at 2 CFR 200.340(c)(1) through (c)(3). Only a NASA Grant Officer may officially terminate an award; however, the decision to terminate an award should be made in consultation with the award’s cognizant Technical Officer. If an award is terminated, the Grant Officer terminating the award must follow the notification of termination requirements established in 2 CFR 200.341, Notification of termination requirement.
7.15 Appealing a Suspended or Terminated Award
This section describes the appeal and reconsideration process that NASA makes available to award recipients concerning suspended or terminated grants and cooperative agreements.
- 2 CFR 200.340, Termination, authorizes Federal entities to suspend or terminate an award in whole or in part (see Section 7.13 Award Termination). After the Federal entity has informed a recipient of its intent to terminate an award, NASA will terminate the award if the recipient:
a. Fails to submit a timely appeal or request for reconsideration.
b. Fails to provide a satisfactory justification to maintain its Federal assistance award.
c. Fails to resolve its non-compliance within the time specified by NASA.
2. Per 2 CFR 200.342, Opportunities to object, hearings and appeals, NASA provides award recipients the opportunity to appeal and provide information and supporting documentation to dispute the decision to suspend or terminate a Federal assistance award.
3. Per 2 CFR 200.342, NASA must comply with requirements for hearings, appeals, or other administrative proceedings to which award recipients are entitled.
4. If a recipient disagrees with NASA’s decision to suspend or terminate, it may appeal that decision in writing to NASA within 30 days of receipt of NASA’s written notice. The appeal shall include:
a. The reason the decision is being disputed and a justifiable reason its Federal assistance award should not be suspended or terminated. The recipient must provide a satisfactory rationale for maintaining its Federal assistance award.
b. Details of the methods to resolve its non-compliance within a time to be reviewed and deemed acceptable by NASA (if applicable).
c. The appeal will be reviewed by the award’s relevant Grant Officer, with concurrence from the Technical Officer. After review, NASA’s initial decision to suspend or terminate an award will be affirmed, modified, or reversed, and this determination will constitute NASA’s final decision.
5. NASA will not take any action to terminate or suspend a recipient’s award until the recipient has exhausted all of its appeal and reconsideration rights, including judicial review.
NSF
A. Suspension and Termination Procedures
1. Definitions
a. SUSPENSION means an action by NSF that temporarily withholds Federal support of a project pending corrective action by the grantee or a decision by NSF to terminate the grant.
b. TERMINATION means the ending of the NSF award, in whole or in part at any time prior to the planned end of the period of performance.
2. Suspension and Termination
a. NSF Policy
(i) A grant may be suspended or terminated in whole or in part in any of the following situations by:
(a) NSF when the grantee fails to comply with the terms and conditions of the grant;
(b) NSF when the Foundation has cause;
(c) NSF when ordered by the Deputy Director under NSF’s Regulation on Research Misconduct (45 CFR § 689);
(d) mutual agreement of NSF and the grantee; or
(e) the grantee on written notice to NSF setting forth the reasons for such action, the effective date, and, in the case of partial termination, the portion to be terminated or suspended (with the understanding that if NSF determines that the unterminated portion will not accomplish the purposes of the grant it may suspend or terminate the entire grant).
(ii) Normally, action by NSF to suspend or terminate a grant will be taken only after the grantee has been informed by NSF of the proposed action, or informed of any deficiency on its part and given an opportunity to correct it. NSF, however, may immediately suspend or terminate a grant without notice when it believes such action is reasonable to protect the interests of the government.
(iii) No costs incurred during a suspension period or after the effective date of a termination will be allowable, except those costs which, in the opinion of NSF, the grantee could not reasonably avoid or eliminate, or which were otherwise authorized by the suspension or termination notice, provided such costs would otherwise be allowable under the terms of the grant and the governing cost principles.
(iv) Within 30 days of the termination date the grantee will furnish a summary of progress under the grant and an itemized accounting of costs incurred prior to the termination date or pursuant to (iii) above. Final allowable costs under a termination settlement shall be in accordance with the terms of the grant, including this section, and the governing cost principles, giving due consideration to the progress under the grant. In no event will the total of NSF payments under a terminated grant exceed the grant amount or the NSF pro rata share when cost sharing was anticipated, whichever is less.
(v) A notice of termination other than by mutual agreement and/or the final settlement amount may be subject to review pursuant to Chapter XII.B.
(vi) NSF will report award terminations to the OMB-designated integrity and performance system in accordance with Federal regulation, but only after the grantee has had an opportunity to exhaust the review procedures contained in Chapter XII.B.
b. Procedures for Suspension or Termination by NSF
(i) When it is believed that a grantee has failed to comply with one or more of the terms and conditions of a grant, the NSF Grants Officer will normally advise the grantee in writing of the nature of the problem and that failure to correct the deficiency may result in suspension or termination of the grant. The grantee will be requested to respond in writing within 30 calendar days of the date of such letter, describing the action taken or the plan designed to correct the deficiency. Copies of such correspondence will be furnished to the PI/PD and to the cognizant NSF Program Officer. NSF, however, may immediately suspend or terminate a grant without notice when it believes such action is reasonable to protect the interests of the government.
(ii) If a satisfactory response is not received within the above period, the NSF Grants Officer may issue a notice immediately suspending authority to further obligate grant funds, in whole or in part. Notice of suspension is sent to the AOR, with a copy to the PI/PD. Within NSF, copies are furnished to the NSF Division of Financial Management and to the cognizant NSF Program Officer. The notice will set forth the terms of the suspension and its effective date.
(iii) Normally, the suspension will remain in effect for a maximum of 60 days to allow the grantee to take corrective action. In the event that the deficiency is not corrected to the satisfaction of NSF, the NSF Grants Officer may issue a notice of termination. The notice will set forth the reasons for the action and its effective date.
(iv) The remedies described in Chapter XII.B do not preclude a grantee from being subject to debarment and suspension under the OMB Guidelines to Agencies on Government-wide Debarment and Suspension (Nonprocurement) published at 2 CFR § 180 and NSF’s Implementation of the OMB Guidelines, located at 2 CFR Chapter XXV.
(v) Suspension or termination due to research misconduct will be imposed as provided in that regulation.
3. Termination by Mutual Agreement
a. NSF Policy
Circumstances may arise in which either NSF or the grantee wishes to terminate a project. If both parties agree that continuation of the project would not produce results commensurate with the further expenditure of funds, or if there arises any other reason, the grant may be terminated by mutual agreement.
b. Procedures
(i) If the grantee wishes to terminate the project, the AOR should advise the NSF Grants Officer in writing and send a copy to the cognizant NSF Program Officer.
(ii) If NSF wishes to terminate the project, the NSF Grants Officer will advise the grantee’s AOR in writing and send copies to the PI/PD and the cognizant NSF Program Officer.
(iii) Within 30 days after receipt of request from either party for termination by mutual agreement, the other party will provide an appropriate written response. In the event of disagreement between the parties, the NSF Grants Officer will make a final decision, subject to the review procedures prescribed by Chapter XII.B.
(iv) Following termination, grant closeout procedures will be initiated.
4. NSF Suspension or Termination Review Procedure
Grantees should refer to Chapter XII.B.3 for procedures to request review of a suspension or termination notice. Pending resolution of the request for review, a notice of termination shall remain in effect
STScI
Source: STScI GGP December 2018
Section 30 – Suspension and Termination
A. Definitions
- The “termination” of a grant means the ending of an STScI award, in whole or in part, at any time prior to the date of completion.
- The “suspension” of a grant is an action by STScI that temporarily suspends a grant award pending corrective action by the grantee, or pending a decision by STScI to terminate the grant.
B. Termination for Convenience
- STScI may terminate a grant award in whole or in part at its discretion, or when it determines after consultation with the grantee, that the continuation of the work would not produce beneficial results commensurate with the further expenditure of funds.
- The termination conditions, including the effective date, and in the case of a partial termination, the portion to be terminated, shall be by mutual agreement to the extent possible.
- The grantee shall not incur new obligations for the terminated portion of the grant after the effective date, and shall cancel as many outstanding obligations as possible.
- STScI will allow full credit to the grantee for non-cancelable obligations properly incurred prior to the termination.
C. Termination for Cause
- When a grantee fails to comply with the terms and conditions of a grant award, STScI may upon reasonable notice to the grantee, suspend the award in whole or in part and withhold further payments or prohibit the grantee from incurring additional obligations of funds pending corrective action by the grantee or a final decision by STScI to terminate the grant award.
- STScI will allow necessary and proper costs that the grantee could not reasonably avoid during the period of suspension provided the costs are in accordance with the terms and conditions of the Grant Award or Amendment Documents and these General Grant Provisions.
- STScI reserves the right to recover grant funds that were unexpended or were spent in violation of the terms and conditions of a grant award.
- The retention of payments by the grantee or recovery by STScI under a grant terminated for cause shall be determined in accordance with legal rights and liabilities of the parties.
D. Termination by the Grantee
- The grantee may terminate a grant by sending written notification to STScI setting forth the reasons for such termination, the effective date, and, in case of partial termination, the portion to be terminated.
- If STScI determines in the case of partial termination that the reduced or modified portion of the grant will not accomplish the purposes for which the grant was made, it may terminate the grant in its entirety under either paragraph B or C, above.
Carryforward
NASA
D8. Financial Management
(d) Unless otherwise directed by the Grant Officer, any unexpended balance of funds which remains at the end of any budget period, except the final budget period of the award, may be carried over to the next budget period, and may be used to defray costs of any budget period of the award. This includes allowing the carryover of funds to the second and subsequent years of a multiple year award. Unexpended funds from one award may not be carried over to a new or different award. This term and condition also applies to subawardees/subcontractors performing substantive work under the award. NASA reserves the right to remove unexpended balances from awards when insufficient efforts have been made by the awardee to liquidate funding balances in a timely fashion.
Pre-award Expenditures
NASA
5.14.1 Pre-award Costs
Pre-award costs are those incurred prior to the effective date of an award directly pursuant to the negotiation and in anticipation of the award where such costs are necessary for efficient and timely performance of the scope of work. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the award. If charged to the award, these costs shall be charged to the initial budget period of the award, unless a NASA Grant Officer specifies otherwise. Per 2 CFR 1800, NASA has waived the requirement for award recipients to obtain written approval prior to incurring project costs up to 90 calendar days before NASA issues an award. However, expenses incurred more than 90 calendar days before the award require prior written approval from a NASA Grant Officer. All costs incurred before NASA makes the award are at the recipient’s risk (i.e., NASA is not required to reimburse such costs if for any reason the recipient does not receive an award or if the award is less than anticipated and inadequate to cover such costs).
NSF
b. Pre-Award Costs
(1) Grantees may incur allowable pre-award costs within the 90-day period immediately preceding the start date of the grant providing:
(a) the approval of pre-award spending is made and documented in accordance with the grantee’s procedures; and
(b) the advanced funding is necessary for the effective and economical conduct of the project (In the case of a renewal award, grantees are reminded that costs incurred under the old grant cannot be transferred to the new grant.)
(2) Pre-award expenditures are made at the grantee’s risk. Grantee authority to approve pre-award costs does not impose an obligation on NSF:
(a) in the absence of appropriations;
(b) if an award is not subsequently made; or
(c) if an award is made for a lesser amount than the grantee anticipated.
(3) Requests for pre-award costs for periods exceeding 90 days must be submitted to NSF via use of NSF’s electronic systems. Pre-award expenditures prior to funding of an increment within a continuing grant are not subject to this limitation or approval requirement but are subject to paragraph (2) above.
Additional information on pre-award costs is available at 2 CFR §§ 200.308(d)(1) & (d)(4).
STScI
Source: STScI GGP 2018
Section 11 – Pre-Award Costs
Pre-award costs are those incurred prior to the effective date of the grant award. The costs must be for project activities directly related to a specific STScI program and necessary for efficient and timely performance of the scope of work. Such costs are allowable only to the extent that they would have been allowable if incurred after the award date of the grant.
Pre-award costs are incurred at the grantee’s own risk. STScI is under no obligation to reimburse such costs in the event that a grant award is not made or if an award is made in an amount less than approved.