Transcript Office of Sponsored Projects For PIs: Managing your Sponsored Project September, 2013 http://www.dartmouth.edu/~osp/ PI HANDBOOK  http://www.dartmouth.edu/~osp/resources/handbook/

Office of Sponsored Projects
For PIs:
Managing your Sponsored Project
September, 2013
http://www.dartmouth.edu/~osp/
PI HANDBOOK
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http://www.dartmouth.edu/~osp/resources/handbook/
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SHARED RESPONSIBILITIES
Stewardship and compliance
 Effective management of public funds/taxpayer
dollars to maximize research outcomes
 Avoidance of serious cases of fraud, institutional
mismanagement, or poor management of
sponsor funds
The ultimate responsibility for the management of
the agency funds rests with the PI
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WHAT PI/DEPT ADMIN. DOES
WHAT OSP DOES
Review notice of award
Monitor spending - budget vs. actual expenses
Keep all participants informed
Process employee paperwork
Monthly reconciliations
Submit transfers (CTs, LADCs & journals)
Subs:
Prepare and submit sub-award requests
Review progress
Review and approve invoices
Prepare prior approval documents
Request no cost extensions
Inform OSP of pending changes:
Project changes
Financial changes
Personnel changes
Provide PI with:
Projections
Portfolio status
Employee verify/sign labor reports
CloseoutProvide final reconciled direct cost $s
Prepare supporting documents of outstanding
debits/credits
Submit timely technical/progress and invention
reports
Monitor the award
Review budget
Review IDC, C/S, allowable & unallowable costs
Labor verification reports by employee
Process sub-award requests
Review/approve those documents requiring prior
approval
Use OGA/IRA Reports
Approve/process:
 No-cost extensions
 Requests for:
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rebudget
change in PI
transfers
Financial reporting
Compliance: interpret guidelines, rules & regulations
Communicate with sponsor
Cash management & collections
Prepare and negotiate F&A proposal
A-133 and other audits
Closeout
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COMMUNICATION
The ultimate responsibility for the management of the agency funds
rests with the PI
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PI must be very familiar with the NOA and its terms and conditions
PI’s responsibility to meet/communicate with the Department/Research
Grant Manager on a regular basis to inform Department Grant Manager of:
 Personnel changes, change in scope
 Supplies and equipment purchases
 Subawards
 No-cost extensions
Department/Research Grant Manager’s responsibility to:
 Keep the PI informed of
 Award Terms and Conditions
 Expenses and remaining balances
 Reporting requirements (including closeout)
 Non-competing and competing renewal budgets and deadlines
 Work with Sponsored Research Manager
OSP’s responsibility to serve as direct liaison with sponsor
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5 Principles of Financial Transactions Management
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Consistency: Transactions must be handled in a consistent manner. Policies and
procedures have been established to address similar types of transactions in a
routine manner.
Timeliness: Transactions must be handled within a reasonable period of time
consistent with time frames outlined for federal agencies, a private sponsor, and
Dartmouth College.
Justification: There must be a reason for the transaction that supports the
project’s goals, and adheres to guidelines outlined by federal agencies, a private
sponsor, and Dartmouth College.
Documentation: Sufficient documentation to support the transaction must exist.
The documentation must be retained, organized and complete enough to stand
up to an audit.
Certification: Transactions must be approved and carry all the correct
authorizing signatures.
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Allowable, Allocable & Reasonable Costs
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Allowability: Expenses charged to a sponsored research award must meet
the following criteria:
 The costs must be reasonable
 The costs must be given consistent treatment through application of
generally accepted accounting principals appropriate to the
circumstances
Allocability: The cost has been incurred solely to support or advance the
work of a specific sponsored research award
Reasonableness: Must be able to withstand public scrutiny
Dartmouth policy takes precedence over sponsor requirements
Reference Office of Management & Budget (OMB) Circular A-21
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Advance Account/Pre-award Spending
Requirements
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PI has a good sense that the proposal/renewal will be funded
Department is responsible for covering the expenses if not funded by the
sponsor
Allowable costs prior to funding
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PI/Department to complete routing form, budget, scope of work
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Payroll
Purchasing of equipment
True pre-award costs
PTAEO String in advance
Internal Advance Account Request form
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Current Conflict of Interest Disclosure (COID)
Invention Agreement must be on file – one time submission
Current/updated CPHS and/or IACUC Approval Number(s)
Department Chair signature required
Department submits the signed form to OSP for their review and approval
Not all sponsors allow Pre-award; OSP to check with sponsor
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Subawards
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PI/DGM/RGM review proposal/NOA for new/existing subawards
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If not in budget/proposal – prior approval (agency/sponsor specific)
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Setup: Submit request to OSP SRM (2 week turnaround under normal circumstances)
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Request must include:
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Statement of work (SOW)*
Budget (even if in proposal)*
Carryover funds need separate budget
*Agreement cannot be prepared and issued if either, or both are not attached
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PI in communication with subrecipient
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Before PI signs off on an invoice, Dept/OSP ensures that:
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There is a fully executed agreement on file with the OSP SRM
Invoices are submitted in accordance with Terms & Conditions of the subaward
There are no duplications of invoices or costs
Invoices include only expenses that are allowable, allocable and reasonable
Expenses follow the budget and are for actual costs incurred during the invoice period
Invoice includes a signed certification statement verifying financial data. The subrecipient PI is usually not
this person
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Subawards cont.
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The PI is responsible for monitoring the periodic progress of the SOW and all invoices
PI’s Review of Invoices for Payment:
 Determine if expenses reported on each invoice align with the technical progress
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PI’s signature attesting to: “In signing below, I approve payment of this invoice
and attest that the charges appear reasonable and progress to date on this
project is satisfactory and in keeping with the statement of work”
 Only the DC PI can approve payment
Non-compliance by subrecipient with technical reporting requirements or DC PI
dissatisfaction with the level of progress should be reported immediately to OSP SRM
Closeout
 PI must verify by email to OSP SRM that all required reports have been
submitted and are acceptable
 Sub-recipient has up to 60 days to send final invoice. If invoice is sent after this
we are not obligated to pay
 If award is not under FDP then subrecipient needs prior approval to carryover
funds
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Payroll
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PI’s responsibility to:
 Make certain that payment of salary or wages to an individual charged
to a given project is commensurate with the individual’s contribution to
THAT project and per agreement/ESNAP Report
 Notify DGM/RGM of any personnel changes
 Notify OSP SRM if there is a 25% or more decrease in salary/effort for
any key personnel. OSP SRM, in turn, must notify sponsor
Largest expense for most projects
PI cannot have 100% effort on sponsored projects- Exclusions: teaching,
writing of grant proposals and other non-sponsored project administrative
duties
NIH Salary cap – key personnel salary cannot exceed NIH salary cap
Salary distribution – notify DGM/RGM of any changes
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Wage Transfers
LADC/Retroactive Labor charges (Wage Transfer form) to move actual salary
charges to or from a sponsored research account
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Need only to supply affected PTAEO strings
Reason/justification to be included in the comment section
Signatures required :
 DGM or FC when $500 (excluding fringe) or less and correction made
within 90 days following the GL Transferred Date found on IRA using
the “Transaction Detail” report
 PI (Dept Chair or equivalent if PI is unavailable) if over $500 (excluding
fringe) and not yet over 90 days following the GL Transferred Date
 PI (Dept Chair or equivalent if PI is unavailable) if correction not made
within 90 days following the GL Transferred Date. The PDF version will
be reviewed but may not be approved depending on the circumstances
 When multiple accounts are involved each PI must sign
Importance of review, reconciliation and communication
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Labor Verification/Certification
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Labor Verifications-By Employee
 Report is generated at the end of the fiscal year
 Employee has to sign, if they no longer work at Dartmouth then
Department Chair should sign
Required by Federal Regulations
Documents and supports salary and fringe benefit allocations - after the fact
(including cost shared effort)
Are we following through on commitments (proposed & awarded)?
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Compensation Funding Agreements
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Compensation Funding Agreement is required whenever a Clinic or Hospital
Employee will be paid off of a Sponsored Research Account
Separate agreement required for each grant/project year
New agreement if any changes in time commitment or rate of compensation
Not included in Labor Verification Reports and do not appear in the Dartmouth
HRMS payroll system
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Reallocation of Charges Involving Sponsored
Funds
Simple Reclassification Journals and Cost Transfers are used to move
expenditures from one account to another.
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Simple Reclassification Journals and Cost Transfers should not be used to
manage sponsored research funds
Frequent journals and cost transfers may indicate lack of proper oversight
Budget must be managed to minimize frequency and retroactivity of
journals and transfers
Expenses must be allowable, allocable, documented, justified and in some
instances approved by OSP
Federal cost principals prohibit transferring expenses from overspent
sponsored research awards to other sponsored research awards
Cost transfers that are over 90 days create an audit risk and are rarely
approved
Late cost transfers will not be tolerated without a solid justification and will
be highly scrutinized by the OSP Sponsored Research Manager
All PIs on the debit and the credit side need to sign the form as well as OSP
Timely corrections avoid deficits and risk of audit
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Simple Reclassification Journal
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Does not require documentation of the expense (invoice copy, transactions
report) nor the PI’s signature. If the correction is made within the month
following the original Transferred Date the transaction may be of any dollar
amount.
If the correction is made with 90 days of the original Transferred Date then
to be considered a Simple Reclassification Journal it must be less than
$500/transaction, or within the same PTAEO string or be moving the
expense from a PTAEO string to a GL account.
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Cost Transfers
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If the transaction is over $500 but not yet over 90 days from the GL
Transferred Date the cost transfer or wage transfer form is completed by
the department grant manager, signed by the PI and is sent to OSP with
accompanying documentation for approval. Processing will be done by OSP
or the appropriate finance center.
If the transaction is over 90 days it is highly unlikely that it will be
approved. Extenuating circumstances that would allow such a transfer
include receipt of an award with a retro start date.
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Most Common Unallowable Costs
Advertising, Public Relations
*Alcoholic Beverages
Alumni Activities
Bad Debts
Cell phones including monthly charges
Internet charges
Charitable Contributions
*Entertainment
Goods/Services for Personal Use
*First Class Air Travel
Lobbying Costs
*Memberships in Community
Organizations, Country Clubs, Social Clubs
Housing of Officers
Selling and Marketing Cost
Fines and Penalties
Certain Legal Costs
Losses on Sponsored Agreements (Overruns)
Fund Raising & Investment Mgmt Costs
Interest Expense for Operating Purposes
*Postage (usually part of indirects)
*Telephone Line Charges and basic monthly charges(usually part of indirects)
*Copying (usually part of indirects)
*Unallowable unless clearly itemized and justified
in the proposal and approved by sponsor
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Travel, Entertainment & Meals
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The PI and department are responsible for adhering to the College travel
policy- see Dartmouth Travel Policy Guidelines (Procurement Office)
All parties are responsible for reviewing Notice of Award for travel terms &
conditions
 Foreign travel – US Carrier
 Is prior approval required
 Department scrutinizes charges
OSP reviews travel charges reported on the Travel Reimbursement Form
when greater than $500 (after the fact)
Purchasing Cards (procards) cannot be used for meals (only for supplies
and equipment up to $2,500) but can be used for take-out and if order is
delivered
Dartmouth Travel Policy takes precedence over sponsor requirements
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Examples of Entertainment & Meal Situations
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After the meeting, the dean of the Medical School holds a reception
for the scientists where beer, wine and hors d’oeuvres are served.
The costs are considered entertainment and are disallowed on a
federally sponsored research award.
The Physics Department receives a sponsored research award to hold
a symposium for leading scientists to discuss a new particle. In its
sponsored research application, the Department listed the activities it
planned to conduct, and the sponsored research award specifically
provided for a working dinner the night before. This would be
allowable on the sponsored research award since there was such a
specific provision.
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Capital Equipment
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Capital equipment is tangible personal property having a useful life of one
year or more and an acquisition cost of $5,000 or more per unit.
Capitalized fabricated equipment that is assembled or manufactured by
the College using purchased materials, in-house machinery or tools and
College labor. Fabricated equipment valued at $5,000 or more and having
a useful life of one year or more shall be capitalized and recorded on the
College’s equipment inventory.
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Statement of Intent to Fabricate an Item form
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Department must contact Procurement Services (Fixed Assets
Coordinator) when equipment is purchased
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No capital equipment may be purchased during the last 6 months
of a sponsored project.
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All equipment purchased using sponsored research funds is the
property of Dartmouth College
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Items Requiring Approval by PI
When involving a sponsored research account
 Advance Account request form
 Request for issuance of a sub-award (or authorized designee)
 Sub-award invoices
 Any invoice greater than $25,000
 Consultant/Independent Contractor form
 Wage transfers
 Cost transfers
 Request for no-cost extension
 Request to carry over funds (when prior approval required by
sponsor)
 Transferring residual funds
 Requesting re-budgeting of funds
 Any other items requiring prior approval from sponsor
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Items Requiring Approval by OSP
When involving a sponsored research account
 Advance Account request form
 Request for issuance of a sub award (or authorized designee)
 Sub-award invoices
 Consultant/independent contractor form regardless of amount and
on invoices covered under an IC agreement if over $5,000
 Requests for payment (RFP) over $5,000
 Miscellaneous Income Payment Vouchers (MIPV) over $5,000
 Any invoice $5,000 or more
 Wage transfers
 Cost transfers
 Journal entries
 Compensation Funding Agreements
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Changes Requiring Prior Approval from Sponsor
Sponsor specific:
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Project relatedness
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Change of scope/salary allocation
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Absence or change in key personnel
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Change in grantee organization
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Indirect cost rate adjustments
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Re-budgeting
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Compensation
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Equipment
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Foreign travel
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Use of unspent balances
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Stipends and tuition remission
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Sub-agreements
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Pre-award costs
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No-cost extension
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Capital expenditures involving buildings, land
Procedure for initiating changes requiring prior approval
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Request should be in writing and made “in advance” of change
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Signed by PI
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Countersigned by OSP
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Cost Sharing
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Cost sharing - project costs not paid for by the sponsor
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May be required by the sponsor (mandatory) or voluntarily offered by the grantee (voluntary)
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Could include anything committed to in the narrative of the budget that will support the project but is
not paid for by the sponsor
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Do not propose cost sharing if not required by the sponsor. Adding cost share to a proposal DOES
NOT increase the probability of being awarded
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Once proposed and/or on the routing form but not in the Notice of Award it is still a commitment and
must be tracked accordingly
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Signed off by fiscal office via routing form; GL account to be provided
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Is a direct cost and is included in the research base for calculating federally approved F&A rate
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Most common types: Salary/fringe, equipment, F&A
Cost sharing is closely reviewed by auditors
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Federal Demonstration Partnership (FDP)
FDP allows:
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One time no-cost extension up to 12 months
 PI submits request to OSP Sponsored Research Manager at least
30 days prior to current end date
 Additional no-cost extensions on the same sponsored research
award require prior approval from the sponsor
90 Day pre-award spending
Rebudgeting within agency guidelines
Automatic carryover
 Refer to agency for thresholds or Notice of Award for restrictions
Expanded Authorities (EA) same terms and conditions as the
Federal Demonstration Partnership
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Continuing the Project
The PI has 3 options for extending a sponsored research project beyond the original date
stipulated in the Notice of Award:
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Non-Competing Continuation
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Competing Continuation
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No=Cost Extension (NCE)
No-Cost Extension under FDP:
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First NCE (up to 12 months)-grantee approved
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Subsequent NCE requests must be in writing and must include the following:
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Estimated balance in directs and indirects
Explanation on why the additional time is needed
Explanation on how remaining money will be spent
The internal DC NCE form must be used/submitted for all requests
Requests need to be sent to OSP 60 days in advance of end date
Requests to be countersigned and submitted to sponsor by OSP
NCE is giving a PI more time to accomplish project goals
NCE cannot be requested simply to use unspent funds
*If the sponsor allows for an email to be sent, then draft letter should be sent to OSP
Sponsored Research Manager. OSP will review and then forward to the Sponsor
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Continuing the Project cont.
No-Cost Extension under non-FDP/non-Expanded Authorities
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Review agency-specific guidelines
PI must prepare detailed letter for all requests
Estimated balance in directs and indirects
Explanation on why the additional time is needed
Explanation on how remaining money will be spent
The signed internal DC NCE form must accompany the detailed letter
Requests need to be sent to OSP 60 days in advance of end date
Requests countersigned and submitted to sponsor by OSP
NCE is giving a PI more time to accomplish project goals
NCE cannot be requested simply to use unspent funds
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PI Transfer/Change of Institution
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Contact appropriate institutional personnel
Contact DC Sponsored Research Manager immediately
 Are grants to be transferred?
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If yes:
 Obtain sponsor approval
 New institution/Personnel contact
 Effective termination date
 If equipment to be transferred refer to policies
 Relinquishing statement
 Fulfill all reporting requirements
If no:
 Sponsor approval for PI replacement
 Effective termination date
 Change in scope?
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Transferring Capital Equipment
Required Procedure for Transferring Capital Equipment:
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Notify Fixed Assets Coordinator in Procurement Services to
remove Equipment Item from Inventory List
A Letter formally requesting the transfer of capital equipment to
another institution and must include:
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Current market value
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Description of equipment (Name, Serial number, Dartmouth
Asset Tag number)
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Signatures of PI, Department Chair, Director of Office of
Sponsored Projects
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Carbon Copy to Fixed Assets Coordinator
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Fully signed original must be sent OSP to be kept in the
sponsored research account file
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Closeout
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PI must prepare and submit timely reports where required:
Technical/Progress
Invention
Property
Federal-Mandatory submission of published works to PubMed Central
Work with Department Administrator/OSP to ensure timely closeout process
Late reporting may result in withheld funding for the PI and/or Dartmouth
College
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Closeout cont.
Records
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Dartmouth retains all original data
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PIs are allowed to keep ‘copies’ of research notebooks when leaving
Dartmouth but the original must stay with the department.
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How long should the records be saved?
 OMB Circular A-110 states (for federal) “generally” 3 years from the due
date of the final report on the sponsored research award
 Sponsor specific
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