Prior to the start of any sponsored research project (federal or non-federal), the Principal Investigator (PI) and Department Grants Administrator (GA) should review the sponsor guidelines, the Office of Management and Budget’s (OMB) Uniform Guidance cost principles, Mass General Brigham (MGB) policies, and the Notice of Award (NOA)  for any expenditure stipulations.

MGB cost charging information can be found on the Research Navigator site (links below):

• Guide to Charging Expenses to Sponsored Projects
• Research Procurement Policy

For NIH-sponsored research awards, refer to section 7.9.
Allowability of Costs/Activities

Remember that the budget is the financial expression of the research project!

All costs charged to a sponsored research agreement must be:

• Allowable
• Allocable
• Reasonable
• Consistently applied
  

Note: Unallowable costs “whether originally budgeted or erroneously charged” must be transferred to the appropriate fund. Refer to the MGB Cost Transfer Policy for more details.

MGB Research Management (RM) has outlined the following scenarios to AVOID:

• Assigning costs to awards based on the remaining balance.
• Assigning costs to an award before the cost is incurred.
• Assigning costs to an award that receives no benefit from the activity.
• Assigning costs to an award that are part of regular administrative support for hospital activities.
• Charging an expense exclusively to one award when the expense supported other or multiple awards.
• Charging the budgeted amount rather than the actual cost.
• Rotating charges without a rotation schedule that reflects the benefit to each project.

The PI is responsible for ensuring that research staff are also trained and informed on cost charging principles. The following sample activities require an understanding of allowable/unallowable expenses on sponsored research awards:

• Ordering lab or office supplies, equipment, computers, telecommunication, etc.
• Approving requisition purchase orders
• Submitting and approving an expense (reimbursement) report
• Booking travel, business meal, event, etc.
• Registering for conferences, membership, etc.
• Approving invoices for payment (subcontract, consultant, publication, vendor, tuition or stipend, etc.)
• Transferring costs and open purchase orders

The PI should contact the GA if there are any questions or if further clarification is needed.

Progress reports are typically submitted on an annual basis and include updates on the scientific/technical progress of the project, as well as information on spending and carry-forward requests. Progress reports may be submitted electronically (e.g., via eRA Commons for National Institutes of Health [NIH] grants) or via email to the agency contact.

Below are the typical responsibilities for the Principal Investigator (PI), Grants Administrator (GA), and Mass General Brigham (MGB) Research Management for progress reports:

PRINCIPAL INVESTIGATOR

• Forward any notifications/reminders that a progress report is due to your GA.
• Provide required scientific/technical information to the project manager and GA.
• For NIH grants, assist GA with language for justification if carry-forward balance exceeds 25%.
• Review information entered for completeness and accuracy. Provide final approval of content.
• Route NIH progress reports in eRA Commons to the MGB pre-award administrator (authorized institutional official). NOTE: This step can only be done under your login even if you have delegated authority to the project manager or GA.

GRANTS ADMINISTRATOR

• If an NIH Progress Report, initiate the progress report in eRA Commons or appropriate agency mechanism specific to the Sponsor.
• Work with the PI and/or project manager to gather the required scientific and project information.
• Work with the MGB Post-Award Administrator to determine carry-forward balance and work with PI to prepare justification if it exceeds the agency threshold (e.g., >25% for NIH grants).
• Review that all information entered is accurate and complete. (NOTE: The PI is still responsible for providing final approval and sign-off.)
• Complete the progress report in eRA Commons and notify PI once it is ready for approval and routing.
• Follow up with MGB Pre-Award Administrator to ensure that the progress report is submitted in a timely fashion.

RESEARCH MANAGEMENT

• Confirm carry-forward balance (Post-Award).
• Review information entered and any attachments provided for completeness and accuracy.
• Provide institutional sign-off.
• Submit to the agency when required/appropriate (Pre-Award).

The Subrecipient Monitoring requirement applies to federal and non-federal projects and continues throughout the lifetime of the award. Responsibility for financial and administrative monitoring of collaborators is shared among the Principal Investigator (PI), Department/Grants Administrator, and Mass General Brigham (MGB) Research Management staff. Responsibility for technical monitoring resides solely with the PI.

All MGB subrecipient monitoring information can be found on the Research Navigator site, links below.

• MGB Subrecipient Monitoring Guidance
• MGB Subrecipient Monitoring Policy
• MGB Subrecipient Monitoring Roles & Responsibilities

Additional BWH Department of Surgery (DOS) Guidance

Subrecipient Invoice Approvals
The DOS Grants Administrator will provide cursory review of subcontract invoice and will notify the PI to complete final review. Cursory review includes (1) verifying expenses are allowable, allocable, and reasonable, and incurred within sub-agreement budget period per the sub-agreement and the prime award; (2) ensuring direct costs, indirect costs, and cumulative expenses are calculated and totaled correctly; and (3) ensuring the invoice dates are within the sub-agreement period.

The PI should correspond with the Grants Administrator prior to approving the invoice. The PI has 20 days (from the initial Insight email notification) to approve in Insight or alert the Grants Administrator to approve on PI’s behalf. Any objection must be communicated within this timeframe to the Grants Administrator and MGB Research Finance. The Grants Administrator or PI will reach out to the administrative contact at the subrecipient to resolve any discrepancies on the invoice.

Compliance
It is the PI’s responsibility to ensure that the subcontracts, including any third parties, have the appropriate IRB and IACUC approvals from their institutions (if ceded review), BWH, MGB, and/or the funding agency according to terms and conditions of the award. The PI should work with the Grants Administrator and MGB Research Management Post-Award to ensure approvals are received prior to performing work. Non-compliance may result in withholding of funds and/or termination of the award.

The Principal Investigator (PI), study staff, DOS Research Administration team, and MGB Research Management all have different sponsor billing responsibilities.

It is the policy and responsibility of MGB Research Management to invoice on behalf of the PI and research team on federally-funded and non-profit sponsored research projects monthly. For the majority of industry-funded clinical trials, the responsibility of invoicing falls to the division/department, specifically the DOS Research Administration team/grants manager.

Regardless of the project origin or Sponsor type, PIs have the primary responsibility for reviewing and confirming all obligations and expenses posted to the fund before generating an invoice.

PI responsibilities include:

• Reviewing fund balances of the project to validate the allowability, allocability, and reasonableness of all costs incurred during the project’s life. (See MGB Research Management’s Sponsored Project Cost Charging Policy)
• Identifying expenses posted to the fund in error.
• Working with the Grant Administrator (GA) on transferring expenses to/from the fund per the MGB Research Management’s Cost Transfer Policy.
• Assisting with the reconciliation of projects with multiple fund numbers to balance appropriate expenses with funding for each fund number.
• Providing additional information necessary to meet the financial reporting requirements of the award.
• Reviewing and approving the final financial report created by Research Finance.
• Ensuring that all technical deliverables are met in keeping with payment milestones and other requirements.

Department Administration responsibilities include:

• Providing regular financial reports for PI to review in preparation for billing/invoicing.
• Assisting the PI with the review of all costs incurred to confirm their allowability, allocability, and reasonableness.
• Assisting the PI with any cost transfer requests.
• Providing MGB Research Finance with additional documentation necessary to complete and submit the invoice when required.
• Assisting the PI with the review of the final invoice created by MGB Research Management.
• Assisting MGB Research Finance in facilitating payment from sponsors for outstanding receivables, when required.
• Maintaining detailed back-up of the project’s activities supporting the costs reflected on the invoice, when required.

MGB Research Finance responsibilities include:

• Preparing, reviewing, and submitting the invoice.
• Obtaining all payments from sponsors for outstanding receivables.
• Providing final confirmation that project expenses are allowable, allocable, and reasonable.
• Providing the PI/ department with a copy of the final invoice.
• Maintaining the official institutional record of invoices generated by MGB Research Management.

Additional BWH Department of Surgery (DOS) Guidance

Effort is the amount of time devoted to a project. It is an area of scrutiny by sponsors because personnel expenses average 60% of research budgets. In the Post-Award stage, the PI is responsible for meeting his/her own “committed” effort on the grant proposal, and for ensuring that the research personnel also meet their committed effort on sponsored grants. This applies to any research staff outside of BWH DOS; the PI and Grants Administrator (GA) should collaborate with the other department’s GA to review/confirm actual effort on a regular basis. It is crucial that the PI direct the GA on any effort changes for the PI and for research staff during monthly review of effort and allocations on all funds.

During progress report submissions, the PI and GA will also report personnel changes in effort of senior/key personnel designated in the Notice of Award and verify that effort matches the current effort commitments.

Effort Changes

Once it has been decided that allocation needs to be adjusted to reflect actual effort (either retroactively or future), the GA will send an email request to the appropriate PeopleSoft tree manager of the PI or staff member to submit an EDC (Earnings Distribution Change) or RPO (Research Post Only) for retroactive changes. The following should be provided to the EDC/RPO submitter:

• Change type: EDC or RPO
• Personnel name
• Effective date
• End date if applicable (note: cannot enter a future end date)
• Percentage (%) changes and business unit/fund numbers (i.e. 2200/123456)
• Brief comment about the proposed changes
  • This comment must include language confirming salaries on sponsored research funds (or the salary allocation) reflect actual or anticipated (for future dated EDCs) effort. If there is a discrepancy between salary and effort, the comment must clarify what the actual effort is in relation to the salary charged.

MGB discourages over-90-days changes in effort allocations on sponsored research funds; it may, however, be necessary in some cases. All retroactive data changes greater than 90 days should include the phrase, “The data change is greater than 90 days because…” followed by justification that answers the five mandatory compliance questions. The following types of EDC/RPOs do not require the > 90-day justification, however, comments explaining the transaction are always required.

1. A personnel transaction transferring salaries to a discretionary fund.
2. A salary allocation placing salary on a newly established fund retroactive greater than 90 days, but submitted within 90 days of fund setup. Department should state the activation date in the comments field.

In many cases, any significant effort changes (i.e. greater than 25% from original committed effort) will require prior approval from the sponsor. The PI and GA should work with MGB Research Management Post-Award to submit a formal request to the sponsor. Once approved by the sponsor, the budget forms, Other Support, and personnel reports should be updated to reflect the change; approval documentation should be saved in DropBox and Insight.

– MGB Research Personnel Transactions

Salary Cost Sharing

In general, during the Pre-Award budget stage, a PI should request equivalent salary dollars for proposed effort on sponsored projects. In some cases, a PI may elect to cost-share the proposed effort. Cost sharing is defined as the portion of a project or program cost not reimbursed by the sponsor. Cost sharing may also be referred to as in-kind contributions or matching funds. MGB discourages cost sharing on sponsored projects unless it is specifically mandated by the sponsor as a condition of the award. Any salary cost sharing will need to be monitored and tracked as part of effort management.

– MGB Cost Sharing SOP

Additional DOS Guidance

As of FY21, the DOS will cover the cost sharing variance for any PI whose Institutional Base Salary (IBS) exceeds the NIH salary cap on NIH grant awards only. During Pre-Award and Peri-Award stages, the GA should contact Jamie Fu and/or Matt Sandler from BWPO Finance to confirm fund number. During Post-Award stage, the GA should work with BWPO Finance to track cost sharing effort, and review with the PI on a monthly basis. For cost sharing on non-NIH grants (either due to grant limitation or voluntary), the PI is responsible for identifying a non-sponsored fund to cover the variance if the grant is awarded.
 

Effort Reporting and Certification

PIs are responsible for verifying the appropriateness of all charges to sponsored projects, particularly those for compensation of personnel services since they generally represent significant expenditures. Semi-annual effort certification is required in October and April. PIs are encouraged to take the Electronic Effort Reporting for Investigators on HealthStream.

– MGB Effort Reporting Policy

Closeout refers to the process that takes place when a grant or contract is ending. The closeout process involves submitting final progress/technical reports, the Final Financial Report (FFR), and, in some cases, invention reports.

Below are the typical responsibilities for the Principal Investigator (PI), Grants Administrator (GA), and MGB Research Management (RM) for closeouts:

PRINCIPAL INVESTIGATOR:

• Submit all required scientific/technical information for the final progress report.
• Review all expenses for allowability, allocability, reasonableness, and consistency.
• Review personnel effort levels for the FFR and/or final invoice.
• Complete the Invention Report and send to GA.
• Review all reports for complete accuracy. Provide final approval of all reports via email or Insight.
• Work with GA to re-allocate all personnel funded on the project closing to another funding source.
• Approve final invoices to the sponsor or prime institution.
• Inform all research staff to stop spending on the fund.

GRANTS ADMINISTRATOR:

• Review fund to ensure that all salaries and expenses have posted to the fund before the FFR and/or final invoice is generated and sent to the sponsor.
• Review fund with the PI.
• Work with the PI and/or research staff to ensure all encumbrances (e.g., open purchase orders) are closed out or transferred to another fund.
• If BWH is the prime institution, ensure that all subaward institutions have submitted final invoices by the deliverable date specified in the subaward agreement.
• If BWH is the subaward institution, ensure that all salaries and expenses have posted before the final invoice is sent to the prime institution.
• Submit all necessary cost transfers or journal entries.
• Ensure that all salaries are moved off the fund via EDC (Earnings Distribution Change)/RPO (Research Post Only) requests before the project end date/salary controls take effect.

MGB RESEARCH MANAGEMENT:

• Process all EDCs/RPOs, cost transfers, and journal entries.
• Review and submit all final reports (technical, financial, invention).
• Generate FFR and final invoices and send to PI/GA for approval.
• Submit approved invoices to the sponsor or prime institution.
• Update Insight fund status to “Inactive.”

Although MGB Research Finance Accounts Receivables is responsible for collecting payment of invoices and drawdown of funds, the GA should also monitor the revenue amounts in Insight Financial Reports.

MGB Billing-Collections SOP

• Generate monthly or quarterly financial reports for all funds, including non-research and research sundry funds.
• Review reports with Principal Investigator (PI) and research staff.
• Complete and submit any salary changes in a timely manner. For MDs, email any salary changes to David Breen in BWPO for submission before the monthly deadline.
• Submit cost transfers and journal entries in a timely manner.
• Alert PI if current spending trend will result in a >25% carryforward for NIH grants or for the applicable agency threshold. Assist with preparing justification for the carryforward request.
• Complete and submit requests for new research and non-research sundry funds.

• Complete quarterly internal effort report and review with PI/research staff.
• Make any necessary effort adjustments for all research personnel.
• Complete biannual MGB effort reporting and route for certification.
• Track salary cost-sharing for PIs if applicable.

• Initiate progress report in eRA Commons for NIH grants or the appropriate agency mechanism for non-NIH grants.
• Work with PI and/or Project Manager to gather required scientific and project information.
• Collect information from subcontracts and collaborators.
• Work with the MGB Post-Award Administrator to determine carryforward balance, and work with PI to prepare justification if it exceeds the agency threshold (e.g., >25% for NIH grants).
• Review that all information entered is accurate and complete. NOTE: The PI is still responsible for providing final approval and signoff.
• Complete progress report in eRA Commons and notify PI once it is ready for approval and routing.
• Follow up with MGB Pre-Award Administrator to ensure that the progress report is submitted in a timely fashion.

• Ensure that all salaries charged to a fund are moved off before the project end date/salary controls take effect via EDC (Earnings Distribution Change)/RPO (Research Post Only) requests.
• Ensure that all expenses are allowable, allocable, and reasonable, and have posted to the fund before a final invoice is generated and sent to the sponsor.
• Work with PI and/or research staff to ensure all encumbrances (e.g. open purchase orders) are closed out or transferred to another fund.
• In instances where BWH is the prime institution, ensure that all subawards have submitted final invoices and other required reports before the sponsor deadline.
• In instances where BWH is the subaward institution, ensure that the final invoice is sent to the prime institution by the deadline.

• Generate financial reports and send them to PI/GA for review and approval.
• Make any changes requested by the GA.
• Provide final approval and sign-off.
• Submit final and signed financial report to sponsor.

• Make any changes to effort requested by GA.
• Make historical edits to effort reports (e.g., the fund is established after the reporting window ends so effort was not entered at that time).  NOTE: This may not be Research Management, but it is done at the MGB-level.

• Work with GA to ensure that carry forward balance information is accurate and assist with language if carry forward amount is >25% for NIH grants (Post-Award).
• Review information entered by GA and/or PI for completeness and accuracy.
• Conduct final review and provide institutional sign-off.
• Submit progress report to sponsor.

• Approve all requests to remove salaries from funds that are ending.
• Ensure that all pending invoices, including from subaward institutions if BWH is the prime, have been paid before the fund is closed and the final financial report is sent to the sponsor.
• Work with GA on closing out open POs and other encumbrances.
• Review, approve, and submit any final progress and/or technical reports depending on sponsor requirements.

The following requests may require prior approval from the sponsor or pass-through entity (PTE). The Principal Investigator (PI) should notify the Grants Administrator (GA) as soon as possible. The GA will work with Mass General Brigham Research Management (MGB RM) Post-Award to review the award terms and conditions, inquire with the sponsor, and determine if a formal request is required.

• Carry-forward unobligated balance
• Re-budgeting
• Changes in the Scope of Work (SOW)
• No-Cost Extension (NCE)
• Changes in effort greater than 25%
• Changes in PI or Key Personnel
• Addition or removal of a subcontract

If a formal prior approval request is required:

1. The PI and GA will draft a formal letter/e-mail, and send it to MGB RM Post-Award.
   • Include any back-up documentation (i.e. budget, justification, etc.)
2. MGB Post-Award will review, co-sign, and submit to sponsor.

If a formal request or approval is not required:

1. The GA will work with MGB RM Post-Award to ensure that the request is documented and updated in Insight.

The National Institutes of Health (NIH) No-Cost Extension (NCE) is available to Principle Investigators (PIs) who were awarded a grant under the NIH’s Standard Terms of Award. Per the NIH, the “NIH Standard Terms of Award include the provision for grantees to extend the final budget period of a previously approved project period one time for a period of up to 12 months, without additional NIH funds, and without prior approval.” This action is known as an NCE. The request for an NCE must be submitted before the project period ends.

Process and Responsibilities

Principle Investigator (PI)

The PI is responsible for determining the need and appropriateness of an NCE. An NCE should only be used under at least one of the following NIH defined criteria:

• Additional time beyond the established expiration date is required to ensure adequate completion of the originally approved project.
• Continuity of NIH grant support is required while a competing continuation application is under review.
• The extension is necessary to permit an orderly phase-out of a project that will not receive continued support.

It should be noted that having unspent funds at the end of a project does not, in and of itself, constitute a valid justification for an NCE.

The NIH goes on the define additional parameters which must be met for an NCE to be deemed appropriate:

• No additional funds are required from the NIH awarding office.
• There will be no change in the project’s originally approved scope.
• There is nothing in the award notice/terms of award that specifically precludes an extension.

Grant Administrator (GA)

It is the responsibility of the GA to alert the PI well in advance of the grant’s original project period end date to allow the PI enough time to determine if an NCE is appropriate. The NCE should be submitted within 90 days of the project period’s original end date.

The GA also acts a liaison between the PI and Mass General Brigham (MGB) Research Management (RM). Once the PI has determined to move forward with the NCE the GA should contact their MGB RM Post-Award Administrator. Only the Signing Official (SO) can request an NCE under the eRA Commons Prior Approval function.

MGB Research Management (RM)

The Post-Award GA is often a designated NIH SO and is responsible for submitting an NCE request. When requesting an NCE, please provide the Post-Award GA with the proposed length of the extension (1-12 months).