Project Implementation and Award Management
Project Implementation
Once a grant is awarded and approved, the Grants Office will schedule an Award Notice meeting with all key stakeholders, including the project team and accounting. This meeting will cover the approved proposal, reporting and invoicing expectations, and a project plan for successfully launching and managing the grant.
Principal Investigators and Program Directors (PI/PDs) are responsible for ensuring that the project is conducted in line with the award’s terms, conditions, and budget. Deans and department heads also oversee compliance with university standards and available funds.
The award notice document provided by the sponsor is used to establish a separate university account for the intended purpose of the award. For the establishment of the account in the amount of the award, the Grants Office furnishes the necessary grant/contract information, including a budget, to the Accounting Office. The Accounting Office notifies the PI/PD of the assigned account number and provides information regarding expending the award.
Post-Award Responsibilities
The Principal Investigators and Program Directors (PI/PD) is responsible for the day-to-day management of the program in accordance with university/sponsor policies and guidelines. Responsibilities include:
The ORG Grants Office is responsible for the non-financial administration of sponsored programs. This includes:
The Accounting Office is responsible for financial administration of all external grants and contracts. Specific responsibilities include:
Award Management and Reporting
Most grants require regular reports related to sponsored activity. Sponsors typically provide specific templates and guidelines, with reporting periods ranging from monthly to annual.
The following types of reports are frequently required by sponsors:
Reports must be reviewed and approved by the Grants Office before submission. The PI/PD and administrators are responsible for initiating and completing the reports, which generally include:
Important: Awards are made to the University, not the individual. Overdue reports can result in the entire institution being barred from future awards.
Time and Effort Reporting
Federal guidance requires confirmation and certification of effort associated with federal awards, which includes effort charged directly to sponsored projects and mandatory cost shared effort.
GCU monitors and documents efforts expended on externally sponsored projects, whether federal or non-federal, in compliance with 2 CFR 200 requirements. All project directors and principal investigators (PI/PDs) for such projects are required to certify their effort and that of other persons active on such projects led or supervised by PI/PDs. Effort reporting is required for all externally sponsored projects, whether federal or non-federal in source. Reports must be signed and submitted to the Grants Office by the 15th of the month after the reporting period ends. Please see the Time and Effort Policy for additional information.
Financial Management and Reporting
The Accounting Office has responsibility for fiscal matters regarding awards. After the award is reviewed and processed, the Accounting Office establishes the sponsored program account and forwards information pertinent to the fiscal management of the sponsored program to the PI/PD. PIs/PDs are provided with monthly expenditure sheets reflecting monthly and cumulative expenditures and encumbrances on a fiscal year basis (July 1–June 30).
The PI/PD is responsible for managing the budget and expending it in accordance with sponsor and university regulations on allowable, allocable, and attributable expenses related to the project, as indicated in the approved budget. Some sponsors require approval of any divergence from budget categories or items. The PI/PD must be familiar with and comply with both the sponsor’s guidelines and the university guidelines for fiscal management of sponsored programs.
General guidelines for expending sponsored program funds are as follows:
Federal regulations (2 CFR 200 and FAR) govern all aspects of financial administration for federally sponsored projects, including allowable expenses and how they are categorized.
The university is subject to an annual audit in accordance with OMB Circular A-133. This audit conforms to specified federal guidelines and serves to certify the effectiveness of the financial management systems and internal procedures. The fiscal integrity of financial transactions is tested, as well as compliance with terms and conditions of federally sponsored activities. The annual audit involves a review of both institutional systems and selected individual program accounts. Financial records and internal oversight are also subject to review by internal audit.
Sponsored projects fall into two categories:
Reimbursement: The recipient must first incur and pay for the project expenses using their own funds. Afterward, they submit proof of these expenditures (such as receipts and invoices) to request reimbursement. Payment is issued after the costs are verified and approved.
Advance Award: Funds are provided upfront to the recipient before the project expenses are incurred. These funds are intended to cover the expected costs of the project. The recipient is required to report on how the funds were spent and may need to return any unused portion if the total expenses were less than the amount advanced.
No-Cost Extension
Although sponsors expect the sponsored program to be completed by the originally specified deadline, some sponsors allow no-cost extensions of the program period. That is, the sponsor may agree to an extended performance period but commits no additional funding to the program.
Among sponsors allowing no-cost extensions, the procedure for obtaining an extension and the amount of time allowed for an extension vary. Some federal agencies authorize the university to grant these extensions internally, within agency guidelines. The PI/PD should contact the Grants Office, well in advance of the program termination date, for information regarding the allowability of and the procedure for requesting a no-cost extension on a project.
Subaward and Subcontracting Procedures
When a sponsored program at Grand Canyon University (GCU) requires that a portion of the work be performed by an external entity or individual, GCU, as the prime recipient and fiscal agent, may issue a subcontract or subaward. This is common when external expertise, facilities, or resources are necessary for the successful execution of the project. The Principal Investigator (PI) or Project Director (PD) must indicate in the proposal any intent to engage a subcontractor or subrecipient to carry out a portion of the work.
Before a subcontract can be issued, most sponsoring agencies require prior written approval. In such cases, the PI/PD must work with the Grants Office to ensure that the subcontract is in compliance with all sponsor requirements. Any regulations or terms applied to GCU as the prime recipient, such as federal regulations, may also apply to the subcontractor. These terms and conditions are “flowed down” to subcontractors and are referenced within the subcontract agreement.
It is important to distinguish between subrecipients and contractors. A subrecipient carries out a portion of the program’s Scope of Work (SOW) and assumes intellectual responsibility, contributing to the project’s overall goals. Conversely, a contractor provides goods or services necessary for the project but does not contribute intellectually. GCU uses this distinction to determine whether a subaward or a service contract is appropriate for the external party.
GCU and its subcontractors must comply with federal regulations such as the OMB Uniform Guidance, which includes specific clauses that must be passed down to subcontractors. These clauses cover areas such as:
In addition, a subaward or subcontract must include a clearly defined Scope of Work (SOW) for the subrecipient, outlining the intellectually significant portion of the project they are responsible for. The subrecipient must carry out the work using its own facilities and resources, while maintaining full responsibility for both creative and intellectual leadership, as well as financial management of their portion of the project. They must also adhere to the sponsor’s terms and conditions, as flowed down from GCU.
Before entering into a subcontract, GCU conducts a risk assessment of the proposed subcontractor. This assessment may include evaluating the subcontractor’s financial stability, compliance history, and capacity to perform the required work. Throughout the duration of the project, GCU, in collaboration with the PI/PD, monitors the subcontractor’s performance to ensure compliance with federal, state, and sponsor-specific regulations. Regular monitoring helps mitigate risks and ensure the timely completion of all project deliverables.
The PI/PD is responsible for initiating the process by working with the Grants Office to develop and formalize the subcontract. The Grants Office assists in drafting the agreement, ensuring all necessary documentation is submitted by the subcontractor. Grants Office staff also work with the subcontractors and PI/PD to negotiate terms that comply with both GCU policies and sponsor guidelines.
Once the subcontract is finalized, GCU’s authorized official, the Provost, will sign the agreement. Prior to this, the subcontractor must sign the agreement and submit any required documentation, such as audit certifications, to GCU.
Subcontractors are required to submit invoices to GCU’s Grant Accountant, who will review the invoices to ensure compliance with federal, state, and sponsor-specific regulations. The Grant Accountant will check in with the PI/PD for approval regarding the subcontractor’s performance. Upon approval, the Grant Accountant will process the payment.
At the conclusion of a grant, the PI/PD is responsible for ensuring that all programmatic and financial reports from the subcontractor are submitted in a timely manner. These reports are crucial for GCU to complete its own final reporting requirements to the sponsor. The close-out process ensures that all obligations are met, both for GCU and its subcontractors, prior to the end of the project.
Subcontracts may be amended or terminated in cases of non-compliance, changes to the Scope of Work, or other project-related issues. Any such changes must comply with sponsor approval processes, and the PI/PD will work with the Grants Office to ensure that amendments are properly executed and documented. In cases of termination, all parties will work together to ensure an orderly close-out of the project.