Ugh…you are a busy professor, checking through your email on a hectic day. There are urgent emails from students, colleagues, collaborators – and then, right in the middle, you see a request from your Sponsored Program Officer. “I see that you are trying to purchase [alcohol? printer ink? a working lunch? etc.] on your sponsored project. Give me a reason why you should be allowed to do this, or I am disallowing this cost right now, causing weeks of clean-up and delays to your research.”
Well, your Sponsored Program Officer will not be that blunt (hopefully). But no matter how friendly and polite this request might be, many PIs see such requests as unreasonable administrative burdens. I recently was forwarded an email from the chair of a department literally said: “Our Office of Sponsored Programs increasingly wants to know how we spent every penny of this money.”
Okay, so maybe that’s not totally fair – but these requests can pile up! That’s why the goal of this post is to fill you in what your friendly research administrator really asking you about the purchase, so you can quickly meet their request and get on with your life. Hit all five of these points, and you will most likely avoid a prolonged back-and-forth tug-of-war with your Sponsored Programs Office.
Is this purchase allowable? Ick, what does “allowable” even mean? Broadly speaking, an allowable purchase does not violate general federal or specific sponsor requirements for what is permissible on a project. For example, alcohol (for social purposes) is not allowed on a federally sponsored project. Period. Taxpayers do not want to pay for your booze. That piece of equipment necessary for your work? Allowable. This link will take you to a fairly good, abbreviated list of unallowable costs, though everything is a bit up in the air with Uniform Guidance. Was the item in question specifically approved in the awarded budget? Then it is most likely allowable, no matter what the sponsor’s regulations typically are.
Is this purchase allocable? If you buy something on a sponsored project, it should be for that project only. Want
to buy beakers, to be used by your entire lab on a variety of projects? That will not fly. The sponsor wants to pay for a specific scope of work to be conducted, and is not interested in funding other scopes of work. Are the beakers going to be used exclusively on your sponsored project? You are good to go. Buying a huge piece of equipment right before the project ends? The sponsor will obviously think this equipment is really for other projects, and might not be pleased with the last-minute splurge.
Is this purchase reasonable? This requirement is so vague, but it essentially boils down to this: Would a reasonable person, using their own funds, purchase this item at this price for this scope of work? An obvious example would be two similar supplies, with one being far more expensive than the other. A reasonable person would choose the cheaper supply. Another example? Just because you are using sponsor funds does not mean you should travel first class to a conference.
Is this purchase covered by F&A? Books, clerical salaries, computers, printers, paper, folders – purchasing any of
these will raise red flags with your Sponsored Programs Office. All of these items should be recovered by the F&A costs your project is recovering. If you make such purchases, it can look like you are “double-dipping.” Is this an essential purchase, and allocable to the project? Your purchase might be okay, though your Sponsored Program Officer will need to make that determination.
Is this purchase going to overspend the project? Sponsored Program Officers will often ask for purchase approval if your project is over-budget or over-committed (will be over-budget if you continue spending the way you intended to currently). Except in rare circumstances, any costs above and beyond the awarded budget will be disallowed.
Work closely with your research administrator on these justifications – I have actually disallowed very few costs in my time, where the PI could provide a justification answering all of these questions. We want to keep your research moving, but also want to make sure the sponsor has no reason to disallow your purchases after the project has ended! Because that is way worse, in the long run, I promise!
I am all for pithy, concise titles – but I seriously wanted this post to be called: “5 Things PIs Should Ask Sponsors Before Doing…though many don’t until it’s too late.” Those ominous words have spelled disaster – mostly in the form of bureaucratic stress – for many a PI.
As a Sponsored Program Officer, I see this happen on a nearly weekly basis. A PI will make a reasonable decision for the health and success of their projects, only to find that a term in their agreement required a sponsor approval to make such a decision. Here are the five approvals I find that PIs most often overlook, leading to last-minute amendments, disallowed costs, and testy sponsors who suddenly are not as enthusiastic about providing a PI with next year’s funding:
Rebudgeting. Anyone in academic has heard or experienced a similar story: A co-PI spontaneously leaves a project halfway through its duration. A piece of critical equipment has a meltdown. Your results are extremely different from what you thought they would be, leading to a new need for different supplies, different personnel, different subawardees. But while the National Institutes of Health (NIH), the National Science Foundation (NSF), and many other federal grant-making organizations may allow you some “rebudgeting authority”, state and private sponsors may not. Others will have a term in the agreement that allows you to rebudget only within a certain percentage of the budget line or total funds awarded. And regardless of the sponsor, most will want to be informed if your scope of work is changing, or if you are adding or removing a subcontract.
Removing a PI. Yes, you thought that assistant professor would be with you forever, helping you with your project. But as soon as Dr. Jones decides to head for greener pastures, it is the lead PI’s responsibility to inform the sponsor, in almost all cases – if the co-PI in question was named on the proposal or award document. Not sure if the sponsor even knew Dr. Jones existed? Talk to your sponsored programs officer, and see what your agreement with the sponsor says. If you specifically agreed to sponsor approval for all key personnel changes, you may still be on the hook.
No cost extensions. So, you are nearing the end of your project, and you still have lots of funds left. Sweet! That means you get to keep all that money, right? In almost all cases, that is incorrect. To keep using the money for your project, will need to extend your project’s end date – which requires a no cost extension. The NSF allows one grantee-approved no cost extension, but most sponsors want you to ask, and provide a justification. And no, “I have money left, so I want to keep this going” is not a good justification. You originally told the sponsor you could have the work finished by the end date – if it’s not done, tell them why.
Change in scope. Across the board, this is the one change every sponsor will want to know about. Even if that weird result in your lab is even more exciting than what you originally proposed, you must send a request to change the goals and outcomes of your research. Until you have that approval in hand, you should keep fulfilling the scope of work you gave the sponsor.
Adding a subawardee. Almost without exception, federal, state, and foundation sponsors want to know when you are partitioning some of your work off to another university or organization. After all, you originally said in your proposal that you could get the work done, so what changed? As a side-note, this emphasizes the importance of identifying subawardees in proposal time – some federal sponsors take up to six months to give approval for new subawardees. If you must ask, ask early, and provide the sponsor with a subawardee scope of work, budget, and commitment letter up front. Waiting for them to ask for these materials only drags out the process.
I get it – sometimes asking for approvals can seem like a drag. But trust me, it is nothing compared to the cleanup work that has to be done when you go behind a sponsor’s proverbial back. And remember – “he who has the gold makes the rules.” You want the sponsor’s gold? Follow the rules. And remember, if you work at a university – your Sponsored Program Officer is always ready to assist!