Communications with External Funding Agencies

Op4.02-1 Communications with External Funding Agencies

Introduction

There are many instances, during the life of an externally funded project, in which communication will be necessary with its external funding source. Prior to award, it may be necessary to negotiate the scope of the project, terms and conditions, and even funding mechanisms. During the project it will be necessary to provide progress and financial reports. In some cases, changes to the agreed upon project may be required. Finally, at the end of the project term it will be necessary to provide final reports, both technical and financial, and there may be a need to work with the agency on project closeout items.

Purpose

This policy applies to all Missouri State University (University) faculty, staff, and administrators who are seeking, or have received external support for research, scholarly and educational projects, and other activities.

To ensure the proper process for communicating with external funding agencies, the policy sets forth the the proper channels to be taken when communication with an external funding agency is required.

Policy

Preliminary discussions with funding sources

Preliminary discussions of program objectives or project scope, by a potential Project Director/Principal Investigator (PD/PI) with a potential funding agency are encouraged and do not require approval through formal channels. However, if the funding is sought in the form of a gift or donation, the PD/PI must contact the Missouri State University Foundation to discuss the process for engaging in such discussions.

Changes initiated by the external funding agency

Changes that are required by an external funding agency to the approved scope of work, budget, or terms and conditions of the project must be coordinated through the Office of Research Administration (ORA) to ensure that the Institutional obligations are officially approved by the Authorized Organizational Representative (AOR).

University requested changes that may require prior approval

Communications between the University and an external funding agency, relative to financial management of projects, are to be coordinated through Grants and Contracts Accounting (GCA). Communications between the University and external funding agencies, relative to programmatic non-financial changes to the approved project, are to be coordinated through the ORA.

In accordance with 2 CFR 200 Subpart D, revisions of program plans and budgets may require prior approval by the federal funding agency. Following are the examples of situations requiring approval by the funding agency.

  • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval).
  • Change in a key person specified in the application or award.
  • The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
  • The inclusion, unless waived by the Federal awarding agency, of costs that require prior approval in accordance with 2 CFR 200 Subpart E as applicable.
  • The transfer of funds budgeted for participant support costs to other categories of expense.
  • Unless described in the application and funded in the approved awards, the subaward, transfer or contracting out of any work under an award, including fixed amount subawards as described in 2 CFR 200.333. This does not apply to the acquisition of supplies, materials, equipment or general support services.
  • Changes in the approved cost-sharing or matching.
  • The need arises for additional funds to complete the project.

No-cost extensions

Principal Investigators are to monitor progress of externally sponsored projects to ensure that the objectives are achieved and deliverables submitted in accordance with these items in the approved proposal. Whenever it is found that these will not be achievable within the approved grant period, it may be possible to obtain a no-cost extension from the sponsor. These extensions are to complete prescribed work not to use unexpended funding. Depending upon the sponsor, there may be a formal process and deadline date for requesting a no-cost extension.

If there is a potential need for a no-cost extension, the Principal Investigator is to contact the ORA to identify the required process and deadlines. The latter may be up to 90 days in advance of the end of the grant period. The ORA will assist the Principal Investigator in preparing the required information for submission to the sponsor. Whenever financial information is required for the request, the Principal Investigator is to coordinate preparation of this material with GCA. The final package will be submitted by the ORA after review and approval by the AOR. Federal agencies have a prescribed process that utilizes the electronic submission, and coordination with the ORA is essential to ensure that these requests are submitted on time.

Transfer of project director/principal investigator to another institution

Should a project director/principal investigator (PD/PI) plan to transfer to another university or terminate Missouri State University employment for other reasons, the ORA should be contacted relative to sponsor requirements applicable to the transfer or termination of an award. For example, the National Institutes of Health requires the submission of "Official Statement Relinquishing Interests and Rights in a Public Health Service Research Grant" when the PD/PI plans to continue the research at another institution. If the PD/PI plans to request the transfer of equipment, Op4.02-11 Equipment Management should be consulted.

Reporting and other communications

Technical communications between principal investigators and their counterparts in the sponsoring agencies are authorized and encouraged, but direct communication between principal investigators and sponsoring agency program directors on matters possibly affecting contractual agreements is to be avoided. Assistance in such matters is readily available from the ORA and GCA.

Any required technical reporting can be submitted directly by the PD/PI unless the report requires AOR approval or includes financial information. Reports in these instances should be run through the ORA so that signature can be coordinated, and financial information verified.