Post-Award & Research Finance Administration
The Post-Award & Research Finance Team serves CHLA with financial management of extramurally and intramurally sponsored grants, contracts, and agreements. The staff is ready to help principal investigators and departmental administrators with the various policies and regulations pertaining to sponsored projects and assist with the successful fiscal oversight of these projects.
The Post-Award team is responsible for preparing and filing financial reports required by sponsors as well as billing and collecting from sponsors. Within the department of Research Operations, the Post-Award & Research Finance team works closely with divisions to support the management of sponsored projects that achieve the instruction, research, public service and outreach mission of Children’s Hospital Los Angeles.
How We Support
The Post-Award & Research Finance team ensures that all projects are set-up and monitored to comply with applicable sponsor and institutional policies and guidelines. The assigned analyst is responsible for the project from startup to closeout. The services provided by the Post Award & Research Finance team include but are not limited to project start-up services, award management and award closeout. It is important to note that central pre and post award activities related to clinical research are led by TSRI’s Contracts and Clinical Research Team.
In addition to the above services, the Post Award & Research Finance team also provides oversight of intramural funding programs, assists with Federal and State audits and administers CHLA’s research core facilities.
Project Start-up Services
Upon receipt of an award notification, the award detail is populated by the Grants team in PeopleSoft then forwarded to the Post-Award team. A post-award analyst is assigned and proceeds with verifying the IDC rate, updating budget detail by budget category per the Notice of Award, generating the award and sending a notification email to Principal Investigator/Division contact once completed.
- Pre-Award Spending
- Project Budgeting
At certain times, the project requires funds to be spent prior to the award period start date. An example is when equipment needs to be ordered ahead of time so that it is available for use at the beginning of the project. In order to begin spending funds, prior approval from the sponsor is necessary. In some cases, the sponsor automatically allows pre-award spending during a certain period before the start date. The departmental administrator and Principal Investigator (PI) should review the award terms and conditions related to prior approval needed from the sponsor. If approval is necessary then the department or PI should forward the prior approval request to the Post Award team for review and submission to the sponsor. If approval is not necessary, the department or PI should forward the request for pre-award spending to the Post Award team for review, approval and subsequent processing of the request and project establishment through a Request for Advanced Spending.
Request for Advanced Spending
Under certain circumstances, PIs may request approval to spend funds in support of a sponsored project in advance of receiving the award from the sponsor or between budget years when the award notice has not yet been received. This is referred to as a Request for Advanced Spending (RAS). The allowability of such costs must be taken into consideration and all standard award documentation requirements, including assurances, must be complete prior to setting up an advanced spending account. The department or PI should submit a completed RAS form with required signatures to the Grants team who will provide an initial review and forward to the Post Award team for approval. The assigned Grants team analyst will process the request and communicate the approval or denial of the request to the department or PI upon receipt of approval from the sponsor to proceed with spending funds.
The initial award application includes a financial proposal outlining the expected project costs in detail, also known as the budget. It is presented as a categorical list of anticipated project costs that represent the best estimate of funds needed to support the proposed work. There are two types of costs that are included in the budget: direct costs and indirect costs.
Direct costs are costs that can be identified specifically with a particular sponsored project, instructional activity, or any other institutional activity, or that can be directly assigned to such activities relatively easily and with a high degree of accuracy. These include but are not limited to:
- Salaries and Fringe benefits
- Travel costs
- Purchased Services
- Patient Care Costs
Indirect Costs or Facilities & Administration Costs
Indirect costs (IDC), sometimes referred to “Facilities & Administrative (F&A)” or “overhead (OH)”are necessary costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved. These include but are not limited to:
- Building Use
- Operation and Maintenance costs of CHLA facilities
- Administrative Support Offices
- Utilities and Other Services
The appropriate indirect cost rate shall be applied to all extramurally funded projects in accordance CHLA policy FIN – 048.0. Investigators and research staff can refer to the Funding Opportunity Announcement (FOA) or agency guidelines to determine whether indirect costs (IDC) are allowable or if a specific rate is required. Any voluntary exceptions to the IDC rate will require an IDC wavier, which should detail the amount of F&A to be waived, and must be approved by the division head, division administrator, and Vice President, Research Operations, prior to proposal submission.
All costs must be given consistent treatment through application of Generally Accepted Accounting Principles (GAAP) appropriate to the circumstances.
All costs incurred on a grant must conform to any limitations or exclusions in 2 CFR 200 or the sponsored agreement, as applicable.
PIs should work with their division administrators to develop a budget which ensures all costs in the budget are fair and reasonable for a research project in accordance with federal regulations, as applicable, and/or agency policies and guidelines, and institutional policy.
Administrative Fee on Gifts: In accordance with CHLA Policy FND – 011.0, Administrative Fee on Gifts, a 10% administrative fee shall be charged on all non-endowment, restricted use gifts to CHLA. Refer to the policy for information on exceptions and waivers.
Cost centers are a set of multiple accounting chart fields which help identify what, where, and how funds are budgeted and expensed on a grant, contract or agreement. Cost centers consist of the following chart fields:
- Business Unit
- Department ID
- Expense Account
- Project ID
Once the project commences and the expenses are incurred, these cost centers will enable the expense details to be captured into the correct accounts.
Subawards transfer a portion of the programmatic work under a CHLA prime award to another institution or organization, a sub-recipient. A subaward is written under the authority of the CHLA prime award and is consistent with the CHLA prime award’s terms and conditions (a grant, contract or cooperative agreement).
A subaward must include a clearly defined, intellectually significant Statement of Work (SOW) to be performed by the sub recipient. The sub-recipient’s SOW is performed by its personnel, using its own facilities and resources and usually at the sub recipient’s site.
The sub-recipient is responsible for adhering to the terms and conditions of the subaward, including those flowed down from the prime award.
Once the award is set-up in PeopleSoft, spending against the funds may begin on the established PeopleSoft-generated project number. The Post-Award team is responsible for reviewing and processing transactions received by the divisions that are associated with sponsored research projects as appropriate; monitoring expenditure activities to ensure compliance with federal regulations, agency specific requirements, and organization’s policies and procedures; reviewing, approving and processing requests for cost transfers, salary reallocations, and no-cost extensions as appropriate; and preparing and submitting interim and final financial reports and issue invoices in a timely manner, as required by the sponsoring agency.
- Cost Transfers and Carryover of Funds
- Award Modifications
Expenditures include all items incurred as part of the project performance and include, but not limited to, capital purchases, non-capital purchase requisitions, check requests, cost transfers (wage and non-wage), employee business expense reimbursements, participant cash fund requests and invoices for services provided by vendors.
It is expected that divisional research administrators with first-hand knowledge of the research activity, in concert with award PIs, review and reconcile their project expenditures on a monthly basis to ensure expenditures are appropriate per the terms of the sponsor agreement and CHLA policy, and are reasonable, allowable, allocable, and consistently applied.
All expenditures incurred on sponsored awards are reviewed by the post-award analyst to ensure they are allowable according to the terms and conditions of the sponsor award agreement.
All expenditures incurred and charged to sponsored projects are assigned a cost center/expense account classification. These accounts inform the PI, division administrations, division analysts, post-award analysts and accounting departments the category to which the cost is related.
CHLA requires all extramurally funded projects to have cost transfers performed no later than (60) calendar days from the end of the month when the expense was incurred. CHLA policy ADM 058.0 governs both wage and non-wage transfers. There are times when expenses are inadvertently charged to a project which has to be retroactively transferred and expensed to the correct project. The division has to prepare a journal to this effect and forward it to the post-award analyst. The post-award analyst will review and verify the validity of the expense, the reason for the transfer and approve /reject accordingly.
Cost transfers may be appropriate in the following circumstances:
- Cost transfers to correct clerical errors
- Cost transfers to reallocate effort to reflect actual charges
- Cost transfers for the removal of unallowable expenses
- Cost transfers for the allocation of costs benefiting more than one project
- Internal cost transfers between non-sponsored accounts
- Cost transfers of out-of-period charges
Carryover of Funds
Carryover of funds is when unobligated funds remaining at the end of the budget period is carried over to the next budget period. However, some awards restrict carryover of funds to a specific budget period. In such cases, prior approval must be obtained from the sponsor to use the funds in the next period.
Please refer to the journal flow chart for cost transfer justification requirements.
Occasionally, certain modifications may be required to the sponsored project award which include but are not limited to: re-budgeting, no-cost extensions, changes in key personnel and changes to the scope of work.
During the life of the award, the PI may determine that a revision of the budget is necessary to best meet the goals of the project. Since awards have specific requirements related to how the funds may be spent, so before re-budgeting is allowed, the post-award analyst will review the terms and conditions of the award agreement for allowability. If prior approvals are necessary, the division and PI should prepare and forward the prior approval request to the post-award analyst. The post-award analyst will review and submit the request to the sponsor.
If prior approvals are not necessary, the PI and division should work with the post-award analyst to proceed with re-budgeting of funds.
No-cost extensions (NCE) are an extension of the period of performance of an award beyond the current end date. This allows the PI to finalize the project with no additional funding by the sponsor, however, unexpended funds from the previous budget period are generally available during the NCE period. A NCE should be requested only to complete the scope of work as laid out in the award agreement and not simply to expend remaining funds.
The department and PI should prepare the NCE and forward to the post-award analyst, which is reviewed, endorsed and submitted to the sponsor.
Change in Status of Key Personnel
Occasionally, it is necessary to change the Principal Investigator (PI)/Project Director (PD) or key personnel of an awarded grant or contract. For federal awards, agency prior approval is required for a significant change in the status of the PI/PD or other key personnel named in the notice of award, including leave of absence during any continuous period of three (3) months or more, or reducing time devoted to the project (effort) by 25 percent or more.
Divisions should refer to the terms and conditions of the award to determine if the sponsor will allow the award to be retained in the absence of the original PI. Generally, sponsors reserve the right to terminate a grant if approval for a leave of absence has not been sought or if the replacement PD/PI or key personnel is not acceptable.
When the sponsor requires prior approval, such requests should be sent in writing to the Grants team for review and approval before they are submitted to the sponsor. To request a change in PI/PD, the current PI or division must initiate the request and route it to the Grants team.
Change in Scope of Work
Similar to change in PI and/or key personnel, there are instances when the scope of work of the project requires modification. It is always important to inform the sponsor of any changes in the scope of work, based on the terms and conditions of the award. Significant changes to the scope of work will require prior approval from the sponsor. The division and PI should forward all supporting documentation regarding the change in scope of work to the Grants team for review and subsequent submission.
Time and Effort Reporting
As an institutional recipient of federal research funding, Children’s Hospital Los Angeles (CHLA) adheres to a Time and Effort certification policy and processes to ensure CHLA remains compliant with federal regulations. Time & Effort Reporting policies and procedures are applicable to all PIs with federally sponsored grants or contracts.
- Effort Reporting & Certification
All Principal Investigators (PIs) at CHLA who have active federally sponsored research are required to certify their time & effort for themselves as well as their associated federally sponsored project staff on a quarterly basis. These certifications confirm that 100% of the direct, or cost-shared, compensatory charges for each individual reflect the commensurate amount of work being performed during a stated period of performance. Effort certification is required by both the federal government and CHLA, and all effort certification is required to be completed in CHLA’s effort reporting system here: https://chla.huronecc.com/ecc/.
Below is a list of helpful FAQs about Effort Reporting at CHLA:
What is Effort Reporting?
Effort reporting is the mechanism used to provide assurance to federal and/or other external sponsors that salaries charged, or cost shared to sponsored awards are reasonable in relation to the work performed. Effort reports are also referred to as “certifications” or “statements.”
What is Effort Certification?
Effort certification is the federally-mandated process of verifying that direct labor charges to, or cost shared on, federally sponsored projects are accurate, timely, and reflect the actual level of work performed. It provides assurance to federal sponsors that salaries charged to federal awards are reasonable in relation to the work performed and that faculty and staff have met their awarded commitments.
Is Effort Reporting Mandatory?
It is the policy of CHLA that all personnel working on a federally-sponsored project, on which part or all of the Faculty or employee’s salary is charged, must certify that 100% of their direct, or cost-shared, compensatory charges reflect the commensurate amount of work being performed during a stated period of performance.
What is the CHLA policy on Effort Reporting?
Children’s Hospital Los Angeles requires PI faculty/employees to certify the percentage of time (i.e., effort) that they devote to the federally funded grants and contracts. Each department and/or division has primary responsibility to ensure compliance with this policy. If effort is not properly certified, salary charges cannot be made against a federal grant/contract.
Please view the policy here: FIN – 045.0 Time and Effort Certification
What is the federal policy on Effort Reporting?
Per the Federal government’s Office of Management and Budget Uniform Guidance-2 CFR 200, Appendix IX—Hospital Cost Principles Under 45 CFR Part 74 Appendix E: Monthly effort reporting is required of Hospitals, and Time & Effort Certification for any personnel paid on a federal grant or contract is mandatory.
How is Effort Reporting managed?
Effort reporting at CHLA is facilitated and managed through a cloud-based reporting system, called eCert. To access eCert as a CHLA-based PI, please navigate to https://chla.huronecc.com/ecc/
How to access training resources for eCert?
All eCert training and supporting resources can be located: https://chla.sharepoint.com/sites/eCert
Who to contact for Effort Reporting assistance?
Please contact firstname.lastname@example.org for any questions or assistance, including how to gain access to the eCert system. If you have effort on a federal contract or grant, you will be required to certify your effort.
Award Closeout Services
The information in this section is applicable to all extramurally funded projects except clinical trial closeouts, which are administered by the Contracts & Clinical Research team. Please refer to this page for information about the clinical trial closeout process.
The Post-Award team assists the division and PI in the closeout process, and the requirements and deliverables are clearly set forth in the award agreement. The assigned analyst refers the terms of the award before monitoring compliance with all final contract and grant reporting requirements. The PI and division prepare and forward the closeout workbook and final invoice to the analyst for review. Once the analyst reconciles the workbook, the final invoice is sent to the sponsor and the Final Financial Report (FFR) is submitted to the agency.
- Award Closeout Process
At the end of the award period, certain administrative actions are required to ensure an orderly and formal closing of the award. According to the Office of Management and Budget (OMB) Uniform Guidance 200.343, all financial, technical and other reports for federal awards are due within 90 days after the award end date.
The PI/Division Administrator will receive award expiration notifications 90-60-30 days prior to the end date and must begin the process of coordinating the financial closeout and termination of the award.
- Division shall perform the final reconciliation of expenditures to project funds and initiate any necessary adjustments.
- Upon final reconciliation of expenses, Division shall prepare and submit a close out workbook to the Post Award team for review. Any necessary adjustments should be justified with supporting documentation.
- Division shall ensure all reoccurring expenses on the award (both payroll and non-payroll) are discontinued or rerouted to a different cost center.
- Upon final reconciliation of the project’s finances, the post award team will de-obligate funding to equal expense and close out the project in PeopleSoft.
In accordance with terms and conditions of the agreement, the Division Administrator, in concert with PI when necessary, will prepare any necessary non-financial and technical reporting documents and submit to the Grants team.
Required Closeout Documents
Based on the terms of the award, the following documents may be required by the sponsor for official closeout of the award.
- Financial Reports
The terms and conditions of the award may require reports periodically and/or a final report. The post award team is responsible for assisting and overseeing the submission of financial reports required by the sponsor.
- Technical Reports
Generally, most grants and contracts require technical report submissions during the period of performance and on a specific schedule. The PI and the division are responsible for preparing and submitting the technical reports to the sponsor. The specific requirements and schedule can be found in the award agreement.
- Property Reports
As part of the closeout process, all federal awards may require a final inventory of equipment purchased during the period of performance. Non-federal sponsors may have other requirements. The PI and division are responsible to adhere to the reporting requirements of the sponsor.
As the last step in the closeout process, the final invoice has to be generated, endorsed and sent to the sponsor. Prior to that, all expenditures have to be finalized and adjustments have to be processed in order to reach a final account balance.
Additional Online Resources
Refer to the links within for additional guidance on award management.
- Online Resources
Office of Inspector General: https://oig.hhs.gov/
California Institute for Regenerative Medicine (CIRM): https://grants.cirm.ca.gov/login/login
Grant Solutions: https://home.grantsolutions.gov/home/services/
NSF FastLane: https://www.fastlane.nsf.gov/index.jsp
Proposal Central: https://proposalcentral.altum.com/default.asp
Wide Area Workflow (WAWF): https://www.dla.mil/HQ/InformationOperations/WAWF/
Health Resource & Services Administration (HRSA): https://www.hrsa.gov/