Grant Writing and Management Guidelines

Pre-award Considerations: What to think about when writing your proposal. Budget Writing budgets and project narrative, salary info, travel/equipment/indirect costs. Award Matches Keeping track of matches, salary match info, supply match info. Sub-contracts Sub-contracting to non-Lesley people or outside organizations.

Post-award Considerations: What to think about after receiving the grant/award. Grant Set-up Principal investigator set-up responsibilities. Bill Payment - Forms Grant Money Carryovers, extensions, final bills. Grants Management and Contracts Construction, contractors, honoraria/consulting info.

The policies and procedures below are intended to aid those preparing proposals and those who manage the day to day activities of an award, such as principal investigators, project managers and administrative assistants. Unfortunately, there are many rules and regulations concerning grants. Why is this so?

The reason is that the money being spent is not actually that of Lesley but that of some other institution or government agency which has entrusted us to manage their funds to carry out specific educational objectives. Since these funds are not the University's, we must exercise greater care and diligence in managing the money. In short, we must be good stewards of these non-University funds.

The person who is responsible for managing the grant is called the principal investigator or project manager. These two terms are used interchangeably throughout the guidelines.

Pre-approval Considerations

1. Budget: Salaries, Travel, Equipment, Costs

You will need to write a budget for all years of the project, as well as a narrative of the project. See Sample Budget, for further help.

Salaries

• The salary section of the budget should list the position or the name of the person to fill the role. Listing only a position should be avoided because the salary amounts cannot be verified. If a new person is to be hired, indicate as such.
• Principal investigators should review, with Human Resources, the level of wages of any persons to be hired with grant funds.
• If grant activities will be accomplished by current Lesley employees, you should indicate in the proposal whether positions will increase the working hours of the person listed, or if the employee will be substituting grant activities for other work. For example, will there be an increase in the person's contracted time with the University above their current full time status?
• Proposals should indicate the amount of time each person is to spend working on the project, in months, days or percentage of total time spent (e.g. 25 percent). The salary used in the calculation of a daily, monthly, or yearly rate should be the employee's 1.0 F.T.E. status. (i.e. Full Time Equivalent)
• Multiple year proposals should include in each salary line an inflation factor of 4 percent for each additional year, to estimate salary increases that are given each year by Lesley University. Lesley's fiscal year is July 1 through June 30. Consideration should be given to the fact that each July Lesley University usually increases salaries. Proposals that will occur over different fiscal years should calculate salary accordingly, using the 4 percent increase as an estimate. (For example, a proposal runs from January through December, the total salary should be calculated using Jan-Jun (6 months) at the current salary rate. July-Dec (6 months) at the current rate plus 4 percent).
• For proposals that do not charge salary for a full year, the following should be the base used to calculate the salary rate. For all employees, the number of days should correspond to 260, the months should correspond to 12. (For example, if a 1.0 F.T.E. is paid $50,000 per year, her daily rate will be calculated $50,000/260 = $192.31. Her monthly rate is $50,000/12 = $4,166.67).
• Fringe benefits should be calculated at 25 percent of direct salaries for all Lesley employees who work at least half-time for the University. Certain salaries (e.g. grad assistants or other student workers, adjuncts, faculty overloads) need only a charge for FICA, which is 7.65 percent of wages.
• If a person on the budget is to receive a consulting fee, they must meet the definition of an independent contractor per Internal Revenue Service code. If an individual is a Lesley University employee, see Honoraria/Consulting Payment Eligibility for additional eligibility guidelines. If consulting fees or honoraria payments are to be paid, they should specifically be listed by name as a line item on the budget. As mentioned above, there are two classifications of people who receive such fees:
• • A Lesley employee working over faculty workload in a consulting capacity. Along with the consulting fee, a charge for FICA (.0765) should be budgeted.
  • A true independent contractor. This is a person or company who is not employed by the University.
   

For items like this, no FICA should be budgeted. Most federal agencies have set a maximum daily rate for consultants. The maximum NSF rate is $548.08 per day. Do not exceed this regardless of the funding source! Whatever amount you budget for consultants, spend within this amount. If you expect to go over, request a budget amendment with the funding source. Some funding sources deny payment for consulting services that go above budget. See Employee Vs. Consultant.

Travel

For all proposals that bid on federal dollars, there needs to be a travel itemization. The breakdown should list the # of trips to be made, # of days of lodging needed, # of days for rental car, etc. Each item should also have a reasonable estimate of cost. The totals for each line item should equal the total travel budget. Effective July 1, 2011, the mileage reimbursement will be $.555 per mile.

Equipment

• Equipment purchases made with external funding must be listed as an item on the budget. (See exceptions in paragraph b.) Any item purchased that is greater than $1,000 is capitalized into the University's long-term assets and inventoried regularly. Any equipment purchased with federal grant money needs to have the title of ownership clearly established, either with Lesley University, with the funder, or with some other school or institution, during the proposal negotiation stage. If there are no provisions addressing ownership, the University retains tentative ownership, with the understanding that the government could ask for the asset back at a later time.
• The National Science Foundation has increased the amount it considers to be equipment to $5,000. Therefore, any items purchased for less than this are considered supplies. However, the NSF rules still require the University to follow its own $1,000 rule and book the item as a fixed asset if it has a life of more than a year. All federally purchased assets are inventoried every two years.
• Equipment should be purchased early in the grant. Do not wait until the last month of the award to make purchases. You must buy equipment used in meeting grant objectives as soon as possible!

Indirect Costs (Facilities and Administrative Expenses)

• An Indirect Cost expense should be part of every proposal, unless the funder specifically disallows recovery of indirect costs. These expenses represents real costs the University incurs that are not covered by the grant, such as heat and electricity. Due to changes in federal guidelines, the term "Indirect Costs" is often now referred to by the term "Facilities and Administrative Expense."
• The official, federally approved, rate for Lesley is 66.4% percent of salaries as of July 1, 2011. Not all Federal agencies allow the approved rate. For example, most Department of Education training grants allow only 8 percent, but this is calculated on the total direct costs, not just salaries. Other restrictions may apply.
• In cases where a professor teaches for two different schools, it should be made clear at the outset which school will get credit for the indirect cost revenue!

2. Award Matches

Some awarding agencies require the University to match a certain amount in order to get the award. Keeping track of matches can be a lot of work for the project manager. Unless a match is needed to be competitive, do not write a match into your proposal. If you must, you will be asked to sign a University form stating that you will be responsible for collecting the backup documentation needed to support the match. This form is entitled Agreement to Collect In-Kind Documentation. Our government and private grant writers have these forms. Outside auditors review the grants each year, and they look to see what kind of support documents you have to prove that the match was met. Do not take this lightly.

• Salary Matches
  Salaries are a common type of match. Be aware that for every dollar of salary match you list, someone is going to have to sign a form stating that they worked the equivalent amount of their salary on your project. You must get commitments from people before you submit your proposal. There is a form for them to sign, which basically says that as long as they are still employed by Lesley, then they will contribute so much of their time to the project. This form is entitled Agreement to Donate In-Kind Services, and is also available from the grant writers.
• Supply Matches
  If you list supplies as a match, then you will need to keep copies of supply items that get paid directly by your department and are not charged to the grant. This can be complicated and hard to track, therefore it is recommended to keep matches as simple as possible!
• Other considerations
  Principal investigators who have not supplied match documentation on grants which have ended will not be allowed to apply for new awards.

3. Sub-Contracts

Sometimes it is necessary to get non-Lesley people or outside organizations to do some of the work in a grant. When the outside firm or individual has a significant impact on the development of the grant's objectives, it is referred to as a sub-recipient. The role of the sub-recipient is greater than a person who is contracted to perform a specific task, such as teach a course or provide graphic design services.

• Sub-contracts are normally drawn up by the Finance Office.
  In addition to the scope of work, period of performance, and dollar amount, many legal provisions are added, as required by the funding source. Sometimes Lesley functions in the capacity of a sub-recipient to other Universities. Large federal grants usually require another organization to evaluate the progress of the grant. If the evaluator helps direct the development of the grant activities, the evaluator is considered a sub-recipient.
• All sub-contracts must be approved by the Finance Office.
  Project managers and Principal investigators do not have authority to sign contracts with sub-contractors. Sub-recipients will be required to submit a budget for the year's work and may be asked to provide documentation as to their financial stability. This is part of the government's requirement that the prime recipient of the award, Lesley, monitor the sub-recipient, as if the University were the government agency.

Post-approval Considerations

1. Grant Set-Up

New grants will be set-up after an award letter has been received by Lesley University, stating the amount of the award and the period of performance. In order for the University to assign a department number to the award, the true funding source must be determined.

Principal investigator set-up responsibilities:

• Provide a copy of the grant award letter and budget to the Finance Office.
• Provide a contact name from the funding source, along with a phone # or email. Sometimes an award appears to be from a private or non-profit organization but is actually money the organization received from a government agency. When the source is federal, additional rules and regulations apply.
• Schedule a meeting with the grant accountant in the Finance Office to review your project.
• Start the hiring process by completing a job requisition for every grant employee who will work on a regular basis. Get the requisition signed by the Dean or Assistant, and forward the form to Human Resources. The form is then sent to the Finance Office for final approval.

2. Bill Payment - Forms and Reports

Lesley uses three forms to pay bills:

• Requisition [doc]
  Completing one of these will generate a purchase order, which will be sent to vendors to authorize goods to be purchased.
• Check Request [pdf]
  Use this when you have received an invoice from a vendor and wish it paid. Attach the invoice to the Check Request form.
• Expense Voucher
  This is used to reimburse people for out of pocket expenses, such as travel or small supply purchases. If the request is to reimburse yourself, it must be signed by you and a supervisor. Vouchers must have all the original receipts attached. Payment cannot be made from photocopies of receipts. Vouchers without backup will be returned to the principal investigator! Vouchers that include reimbursement for mileage should use the current rate of reimbursement, which is $.555 per mile as of July 1, 2011.
• The Expense Voucher is also used to pay people for services rendered, above and beyond their regular salary, as well as non-Lesley workers. If a consulting fee or honorarium payment is requested, appropriate backup must be attached.. An invoice should be submitted as backup for all consulting payments. A time sheet should be included for any Lesley employees. Both invoice and time sheet should provide the following:
• • The name, address and social security number of the person being paid.
  • The number of hours or days that payment is requested.
  • The hourly or daily rate being charged or adjunct rate.
  • The dates that services were performed.
  • A summary of the service performed.
   

NOTE: Vouchers without backup will be returned to the principal investigator! Please see additional information regarding completion of expense vouchers onthe Accounts Payable site.

Time and Effort Reports

An Effort Report is a form listing how an employee's work is divided into different areas. Most forms are prepared by the Finance Office and sent to employees working on grants. Employees sign the form and have their supervisor sign. The form is then returned to the Finance Office.

This documentation is a requirement of OMB A133, a set of rules governing the management of grants. Under A133, grant recipients must have a system of properly charging an individual's time worked (effort) on grants and contracts. This allocation must be reasonable and reflect the time spent working on the grant.

To standardize our method of accounting, Lesley will apply this reporting procedure to all grants and contracts, whether federal or not. Honoraria payments are considered work beyond regular duties. Effort reporting does not apply to honoraria. (The back up document included with the voucher takes the place of the Effort Report.)

1. Principal investigator Responsibilities:
   Each principal investigator should identify the tasks for which each employee is responsible. This is to ensure that when asked by auditors where employees spent their time, the principal investigator will mirror what was documented initially in the grant files and what was actually charged. Incidentally, an individual's salary cannot be charged 100 percent to a grant or subcontract if the person is doing other tasks, such as attending meetings or advising students.
2. Time Covered by Effort Reports
   Most employees need only sign six-month reports, which the Finance Office will prepare. Some employees may need more frequent Effort Reports. This Effort Report will be verified and signed by the employee and principal investigator or department head. These statements are normally prepared for the six-month periods ending June and December.
   
   The principal investigator should be prepared to discuss and justify effort expended by their employees. Since payroll is one of the most frequently abused areas of grant funds, auditors pay special attention to it.
3. Beware of Vacation Pay!
   Employees who will be terminated after a grant ends should use up all their vacation time before the end of the grant. Principal investigators should be aware of the pending end date on their grant or contract and let their employees know that they should use up their time. The budgets do not have funding for unused vacation time which exceeds the annual budgeted pay. If unused vacation time remains at the close of a grant, and an employee terminates, then any payment made to an employee for the time will be charged to the principal investigator's school or department.
   
   Employees who leave in the middle of the year are especially apt to have unpaid vacation. Therefore, principal investigators should inform all new employees that they must use their vacation time before they give notice. Their termination date should be after any vacation days are used.

3. Grant Money - Carryovers, Extensions, Final Bills

Carryover Grant Money

Carryover grant money from one year to the next requires approval of the funding agency. The Principal investigator, not the Finance Office, is responsible for obtaining the approval for carryover. Since each funding agency may have different policies for carryover, the principal investigator should inquire of their funding contact for specific instructions on how to proceed with a request for carryover.

Extending the Life of the Grant

Project managers who will not complete all of the grant's objectives in the allotted time will need an extension. The principal investigator should contact the appropriate funding agency and request one. NSF funded projects allow a 6 month no cost extension of time. Other agencies may vary with their policies.

Payment of Final Bills

Final expenses on a grant or contract should be paid within 30 days of the grant or contract end date. Invoices must, however, be dated within the project period.

Getting the Money from the Funding Source

The Finance Office will be responsible for billing of grants and contracts. Invoices will be sent to the funder according to the instructions in the contract. Principal investigators are not to invoice the funding source. Unless otherwise stipulated in the contract, invoices will be sent on a cost reimbursement basis. The requests for reimbursement will be sent as expenses are incurred. Some funding sources like to make advance payments or pay on an installment basis.

4. Grants Management and Contracts

Grant Contracts

Most government funded grants require the signing of a formal contract. When you receive one, send it to the Grant Accountant, who will review it and get the necessary signatures. There are several different types of contracts. The type of agreement that will apply to a particular project will usually be determined by the funding source. There are commonly two types.

1. Cost reimbursement:
   This type of contract is based on the assumption that we only are paid for what we spend. A budget is negotiated between Lesley University and the funder. The budget assumes that all costs will be incurred and that the total amount of the budget is a maximum that will be paid by the contractor. The budget is an agreed upon list of expenses between the principal investigator and the contractor. Federal contracts usually are awarded on a cost reimbursement basis.
2. Fixed Fee or Fee for Service:
   This type of contract is less common and is based on an end product. (Some cost reimbursement contracts also specify deliverables.) The contractor agrees to pay an amount that was negotiated in the budget. The subcontractor only has to perform the duties agreed upon, and to present the contractor with a finished product. Compensation will be paid according to the dollar amount in the contract. Any remaining funds from a fixed fee contract will be taken as facilities & administrative income by Lesley University.

Other Considerations - Cost Reimbursement, Expiration Dates, DOE/BHE Tips

• If cost reimbursement grant or contracts come in under budget, unspent proceeds will be returned to government agencies.
• The expiration date of the grant is the last day to incur costs. This is the last date purchases can be made and effort expended.
• The principal investigator has 30 days after the end date of a grant or contract to account for moneys expended. This means that all financial obligations of the grant or contract should be resolved by this point. All vendors should have been paid for supplies ordered or services rendered. If there are still invoices not yet received from vendors, then the principal investigator should notify the Finance Office of this and pursue the vendor for an invoice. Any returns of supplies should be completed and credits on account received.
• When dealing with the Massachusetts Department of Education or the Board of Higher Education, it is in your best interest to get what they tell you down in writing. When possible, use email and save their responses. Following up is key!
• Do not be dismayed by what seems to be an exceedingly legalistic and bureaucratic system of grants management. We at the Finance Office are here to help you.

Construction

New construction financed by federal sources has many restrictions on payments made to employees of subcontractors. Under the Davis-Bacon Act, contractors and sub-contractors must pay the prevailing wage rate for the Boston area, as determined by the Secretary of Labor. The law requires the grant recipient to take an active role in monitoring the sub-contractors to assure that proper rates are being paid. Rates are available from the Federal Register or the Department of Labor.

Employee Vs. Independent Contractor Information

Employee Required to comply with employers instructions about when, where and how to work. Works full-time for the employer Hired by the employer Subject to dismissal; can quit without liability. Works at employer's premises. Has a continuous relationship. Work done personally. Performs services under the company name. Paid a salary; reimbursed for expenses; participates in a company's fringe benefit program. Furnished tools, equipment, materials and training.

Independent Contractor Sets own hours; determines own sequence of work. Works for other employers; services available to the public. Hired by leasing company; self-employed. Under a contract that governs how the relationship can be severed. Works off-site. Works by the job. Permitted to employ assistants. Performs services under the worker's business name. Payment by the job; opportunity for profit and loss. Furnished own tools, equipment and training; substantial investment by worker.

Honoraria/Consulting Payment Eligibility

Faculty:

• Work to be completed is during the summer months, when a non-contract status exists.
• Work is completed in an "overload" capacity for the faculty member. This overload status has been approved by the Dean.

Appropriate documentation and backup are necessary for approval of this status.

Administrative and Support:

• Work performed resulted in an overload of different projects.
• This workload goes beyond the original budget plan for the staff person.
• The work will be completed during the same time frame as the original budgets.

Appropriate documentation and backup are necessary for approval of this status.