UNMC is obligated to the sponsor to act as a good steward of the entire award and must therefore monitor the activities of any sub-sites.
For more information on Sub-recipient Monitoring obligations, see UNMC Policy #6108.
Progress Reports to the Sponsor (Non-competitive Renewals)
What is a progress report?
Most sponsors require a progress report at specified intervals, which may be monthly, quarterly, or annually. Progress report requirements are described in the notice of award.
These progress reports are sometimes used to adjust the next year's budget. For grants, although the sponsor may commit in the initial award to several years of funding, the grant award is contingent on satisfactory progress. NIH and NIH-style awards are usually funded in one-year budget periods as part of a five- (or less) year “cycle.” A “non-competitive” continuation of the project is triggered by the submission of a satisfactory progress report. Contracts can be revoked entirely if desired outcomes or performance milestones are not reached. It is very important to communicate to the sponsor in advance of the progress report if there are any circumstances that have adversely affected progress.
The NIH uses an electronic Research Performance Progress Report (RPPR) system for most progress reports (NOT-OD-13-035). The RPPR provides a uniform format for interim performance reporting on federally-funded research and research-related activities.
Who submits the progress report?
The PI prepares the technical report and submits to SPAdmin for review and submission. SPAdmin’s review determines whether the report contains the required elements and is in the proper format.
Internal forms are required prior to progress report submission for projects funded in one-year budget periods as part of a five (or less) year cycle. For more information see Research Administration for Grants and Subcontracts.
Sponsored Programs Accounting prepares and submits the financial report based on the information in SAP, UNMC’s accounting system. Financial reporting and invoicing often occur simultaneously.
Changes Requiring Formal Approval by the Sponsor
Most grants and sponsors allow the investigator some flexibility to change budget and project implementation from that originally proposed. However, many contracts and sponsors require formal approval by the sponsor via an amendment or revised notice of award. SPAdmin will submit the change request to the sponsor.
Some of the changes that typically require formal approval include:
- Change in PI or Key Personnel. UNMC must seek prior sponsor approval if the PI or other key personnel withdraw from the project or are replaced.
- Rebudgeting. Significant variance may occur between budget and actual costs in a funding year; and actual expenditures may be reported for grants to the sponsor via financial reports. If actual costs differ significantly from what was anticipated, it is wise to inform the sponsor. Significance varies with the sponsor, but NIH will require a justification of any change of 25% or more.
- Leave of Absence. Generally, UNMC must seek prior approval from the sponsor if the PI or other key personnel will be absent from the project during a continuous period of 3 months or more, whether for illness or other cause.
- Change in Effort. When a certain level of effort is stated in a proposal, UNMC commits to the sponsor that the named person will spend that time on the project, either paid for by the award or cost-shared by UNMC. Though month-to-month time may fluctuate, the individual must spend the stated average over the project period unless percentage of effort has been changed. It is also important to inform the sponsor if the principal investigator or other key personnel effort is significantly changed. For federal sponsors, approval is generally required if the PI or other key personnel will reduce time devoted to the project by 25 percent or more from the approved level.
Change in Direction or Project Scope. It is also wise to contact the sponsor if the project moves in a new or unexpected direction. Indicators of a change in scope include:
- Change in specific aims approved at time of award
- Change from approved use of live vertebrate animals (including change of species) or involvement of human subjects
- Shift of research emphasis from one disease area to another
- Application of a new technology
- Adding a new subcontract or an international component
Your SPAdmin grant specialist should be contacted if a significant change has occurred that requires sponsor approval.
If additional work is required to complete a project, an award may be extended in one of two ways, depending on sponsor requirements:
- Under “expanded authorities,” SPAdmin can extend the end date and notify the sponsor of the change.`
- If “prior approval” is required, SPAdmin will request a revised Notice of Award or amendment from the sponsor.
In either case, the investigator will be required to submit an explanation (e.g., slow patient accrual, delay in completing last experiments or data analysis).
UNMC cannot extend a project solely for the purpose of spending remaining funds.
When your funded grant is completed, if there are ongoing research questions that the sponsor is interested in, the investigator can often submit the project as a competitive renewal. A competitive renewal requires a new application submitted for peer review, much like the original application. UNMC’s internal process for competitive renewal submission and approval mirrors that of new applications.
SPAdmin verifies effort availability at the time of award, but after the award, the Office of Management and Budget's Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires the investigator certify the salary charged to a sponsored project is reasonable in relation to the effort expended on that project. Per UNMC’s Effort Reporting Procedure, “effort” is the proportion of time spent on any activity, expressed as a percentage of total time.
Total effort for an employee must equal 100% of the employee’s appointment. Investigators are responsible for assigning effort to all personnel on sponsored project budgets and for monitoring effort for all budgeted personnel, including tracking effort changes. If changes in effort occur, investigators are responsible for informing the sponsor.
For more information, see UNMC’s Effort Certification Policy #6105
Sponsored Programs Accounting (SPAccting) initiates and administers Effort Certification reporting. Investigators or delegated staff with first-hand knowledge are responsible for completing the Effort Certification Reports in Research Support System (RSS) on the UNMC intranet.