Forms, Policies & Procedures

NSF Two-Month Rule Policy

As a general policy, NSF limits the salary compensation requested in the proposal budget for senior personnel to no more than two months of their regular salary in any one year. It is the organization’s responsibility to define and consistently apply the term “year”, and to specify this definition in the budget justification. This limit includes salary compensation received from all NSF-funded grants. This effort must be documented in accordance with 2 CFR § 200, Subpart E, including 2 CFR § 200.430(i). If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice budget.

Under normal budgeting authority, a grantee can internally approve an increase or decrease in person months devoted to the project after an award is made, even if doing so results in salary support for senior personnel exceeding the two-month salary policy. No prior approval from NSF is necessary unless the re-budgeting would case the objectives or scope of the project to change.

University Post-Award Guidance

By this policy, NSF intends to limit the amount of funds institutions request from NSF, and therefore the amount NSF will award. Departments should review the proposal budget, budget justification, and award notice to confirm if compensation in excess of two months was already approved within the NSF award. If not already approved and additional effort in excess of two months is required to successfully address the research aspects of the proposed project, submit a re-budget request for internal approval. NSF prior approval is necessary if the objectives or scope of the project change.

Although the NSF two-month rule identifies the salary limit as applicable to “any one year”, for award expenditures UD has defined the year as September – August. Departments should routinely reconcile budget versus expenses, and conduct an annual fiscal review of salary expenditures for the one year period (September – August). Lack of approval and appropriate justification can lead to removal of the salary in excess of two months.

Related Links

NSF Proposal & Award Policies & Procedures Guide (PAPPG)

The complete policy and more can be found on the UD Research Office’s web site.

Outside Employment

1. SCOPE OF POLICY
   This policy addresses employment outside of the University and applies to all exempt and non-exempt employees.
2. POLICY
   The first duty and responsibility of University employees is to render to the University the most effective service possible. No outside service should be undertaken that might interfere with the discharge of this prime responsibility or bring the employee into conflict with the interests of the University.

   The University will assume no responsibility for outside services rendered by eligible employees, and it must be made clear to any person with whom the University employee works that the work has no official connection with the University. …

The complete policy and more can be found on the General Counsel’s web site.

PI Eligibility

Principal Investigators and Co-Principal Investigators have primary institutional responsibility for providing scientific/technical leadership and administrative and financial management of sponsored projects. As such, the University has designated the following personnel as eligible to serve as Principal Investigator or Co-Principal Investigator on sponsored projects*:

• All full-time faculty regardless of academic rank
• Visiting faculty/visiting scientists during the time they draw salary support for the performance of the sponsored project through the University
• Adjunct faculty during the time they draw salary support for the performance of the sponsored project through the University
• Full-time, academic non-administrative professionals in classified positions at or above Level 31E
• All full-time postdoctoral fellows* and researchers
• Under exceptional circumstances documented in writing, other qualified individuals may be designated as a PI. Such designation requires the approval of the Vice President for Research, Scholarship and Innovation, and must be endorsed by the chair of every unit and the dean of every college in which the research project is to be performed. If granted, this PI designation is limited to the proposed research project under consideration, i.e. it does not afford blanket status to serve as a PI on other proposals. To qualify for an exception, the following criteria must be met:
• Only individuals identified to the external sponsor as a PI or CPI in the submitted proposal need to have the PI eligibility approval form completed
• The proposed research must be a programmatic priority of the University
• There must demonstrably be no qualified member of the UD faculty who is capable of serving or available to serve as the PI
• The proposed PI must possess the academic and experiential qualifications that are prerequisite to service as a PI at UD, and his or her participation as the PI must be demonstrably necessary for the successful funding and execution of the research project
• The proposal PI must enter into a signed contract with the University assuring that (a) the work will be conducted in accordance with the high standards of quality expected of all PIs; (b) the PI will comply with all University policies relating to the conduct of research; and (c) the research project will be conducted consistent with all federal laws, rules, and regulations relating to the conduct of research
• Completion of the Research Office PI approval form and submission of a curriculum vitae (CV)

* Principal Investigator/Co-Principal Investigator status may be rescinded for cause.

*A PI approval form is required to permit postdoctoral fellows to serve this role

If an exception is made to make someone an eligible PI and that person isn’t a full-time University employee, the chair or dean must be a co-PI on all proposals for that person.

Retired Faculty Serving as Principal Investigators

Some faculty members wish to continue their research programs after retirement from the University, but do not qualify for status as principal investigators because they are no longer full-time UD employees. Retired faculty members may apply for PI status using the existing Research Office PI approval form.

If the request is approved, retired faculty members may serve initially as co-PIs on proposals with a full-time faculty member as PI (this would typically be the department chair or another senior faculty member). If the proposal is funded and the retired faculty member is hired to work on that grant, he or she may then serve as the PI during the life of the grant. At the time of hiring, the retired faculty member may be appointed to an appropriate professional staff position (such as, for example, senior research fellow), but under no conditions may be re-hired on the faculty (as, for example, a research professor).

Graduate Students as Principal Investigators

The Research Office acknowledges the importance of permitting graduate students to lead sponsored projects where appropriate. There are several sponsors who offer pre-doctoral grants whereby the work is conceived of and carried out entirely by a graduate student. In these cases, a faculty member is identified as a mentor and oversees the project nominally. (examples: NASA: Harriett G. Jenkins Predoctoral Fellowship Program (JPFP), NIH: Ruth L. Kirschstein National Research Service Awards for Individual Predoctoral Fellowships (F31) to Promote Diversity in Health-Related Research, NIH: Predoctoral Training at the Interface of the Behavioral and Biomedical Sciences, DOE: The National Methane Hydrates R&D Program – Graduate Fellowship Program).

To that end, the eligible PI approval form may be used at the time of proposal routing to permit the graduate student to have this role. Also, please have the department administrators ensure the graduate student’s supervisor code is associated with a chair and dean code. This will allow the proposal approval web form to be routed appropriately. The required completed form must be sent to the Research Office at least ten (10) working days before the deadline for submittal of the proposal to the funding agency.

There are still other sponsors for whom the need for submission and approval from an Authorized Representative of the University is not required. The student may submit these applications directly to the sponsor without coordination with the Research Office or a PI eligibility form (examples include: NSF Fellowship, Ford Foundation Diversity Fellowships for Achieving Excellence in College and University Teaching).

If there are questions concerning which type of funding the grad student is applying, contact the Research Office for guidance.

Residual Balance Transfer

1. POLICY

   The Residual Balance policy sets forth the final disposition of residual balances on Fixed-Price, Fixed-Rate, and Non-Refundable grants and contracts at the University of Delaware (UD) in which no designation was made by the sponsor as to the use of any unexpended balance.

   This policy sets forth the requirements for justification, approval, and management of unexpended balances for Fixed-Price, Fixed-Rate or Non-Refundable contracts. If assurances and justifications are provided per this policy, an unexpended balance may be transferred to the appropriate residual account defined by the administering department.

   Residual balances will be distributed proportionately between direct costs and F&A costs, with the direct cost amount being transferred to the administering department. The F&A costs will be transferred to the Central F&A pool.

   All residual balance requests require a Residual Balance Transfer form be completed and submitted to the Research Office for processing.

Related Links

• Residual Balance Transfer Form

The complete policy and more can be found on the General Counsel’s web site.

Sponsored Project Cost Transfer Policy

1. SCOPE OF POLICY
   This policy outlines University of Delaware (“UD” or “University”) requirements for cost transfers to or from a sponsored project, and applies to all University departments, units, faculty, staff and students involved in externally sponsored research.
2. DEFINITIONS
   1. Cost Transfer – An after-the-fact reallocation of a cost to or from a sponsored project. Cost transfers must meet conditions for allocability, allowability, reasonableness and consistency established under federal guidelines.
   2. Untimely Cost Transfer – An after-the-fact reallocation of a cost from or to a sponsored project that is submitted more than 90 days after the original transaction date.
   3. Cost Principles – Fundamental conditions for ensuring costs are permissible on a sponsored project, including:
      1. Allowability or Allowable – Costs must be permissible under the terms and conditions of the award, including the authorized budget and applicable regulations
      2. Allocability or Allocable – Costs must provide a sole benefit to the sponsored project or provide proportionately assignable benefits to the sponsored project.
      3. Reasonableness or Reasonable – Both the nature of the goods or services acquired and the amount paid must reflect the action that a prudent person would have taken at the time the decision to incur the cost was made.
      4. Consistency – Application of costs must be given consistent treatment within established University policies and procedures; costs for the same purpose must be treated and classified the same way under like circumstances.
   4. Principal Investigator (“PI”) – The individual designated in a grant or contract to be responsible for ensuring compliance with the academic, scientific, technical, financial and administrative aspects and for day-to-day management of the sponsored project (grant or contract).
   5. Sponsored Projects – Externally-funded activities in which a formal written agreement (i.e., a grant, contract, or cooperative agreement) is entered between the University and the sponsor.
3. POLICY STATEMENT
   The purpose of this policy is to ensure University compliance with applicable cost principles and federal regulations set forth for cost transfers per Office of Management and Budget (OMB) Circular A-21 and Uniform Guidance 2 CFR 200. Key guidelines under this policy include:
   • Cost transfers must meet conditions for allocability, allowability, reasonableness and consistency established under federal guidelines.
   • It is the primary responsibility of a PI, with support of the department research administrator and the department chair, to determine if all cost transfers are allowable, allocable, reasonable, and applied consistently.
   • Cost transfers should be submitted within 90 days from the date the transaction is originally charged to the sponsored project and must be fully documented and have appropriate authorization.
4. POLICY STANDARDS AND PROCEDURES
   1. Allowability Considerations
      1. The University recognizes that cost transfers are sometimes necessary to correct bookkeeping or clerical errors in the original charges and to allocate closely related work that may support more than one project.
      2. Cost transfers must meet conditions for allocability, allowability, reasonableness and consistency established under federal guidelines.
      3. It is the primary responsibility of a PI, with support of the department research administrator and the department chair, to determine if all cost transfers are allowable, allocable, reasonable, and applied consistently.
      4. Under no circumstances may costs that benefit one sponsored project be charged temporarily on another sponsored project. Failure to adhere to this procedure will result in improper financial reporting and inappropriate reimbursement from the sponsor.
      5. Frequent, late, and inadequately explained transfers, especially those involving projects with cost overruns or unexpended balances, raise serious questions about the propriety of cost transfers and call internal fiduciary controls into question. This may result in audit disallowances and monetary paybacks including penalties and fines.
      6. The table below provides common examples for determining whether a cost transfer is generally allowable, questionable, or unallowable:

   Generally Allowable	Questionable	Generally Unallowable
   Correcting clerical errors or mistyped entries Transferring approved pre-award costs from non-sponsored funds to sponsored projects Reallocating costs originally charged to a central administrative location, or when multiple projects benefit Reallocating salary expenses to match effort distributions Transferring between the primary project and subprojects, unless otherwise restricted by the terms and conditions of the award Transferring when prior written approval has been received from the sponsor	Reallocating expenses between sponsored projects when one is in overdraft Transferring expenses to bring an available balance to zero Correcting salary which has previously been certified in an effort report Transferring an expense that has previously been transferred on a separate occasion	Transferring expenses incurred after the sponsored project end date Transferring expenses with insufficient supporting information or justification (“to correct error” or “to transfer to correct project” are not considered sufficient reasons for transfers) Transferring split expenses without an adequate basis or insufficient documentation for determining whether the split is appropriate due to insufficient documentation Transferring expenses between award project periods Untimely cost transfers without justification for the delay and an extraordinary situation adequately documented

5. Timeliness of Cost Transfers
   1. Original charges should be directed to the appropriate benefiting sponsored project. If it is necessary to process a cost transfer that involves a sponsored project, a journal voucher should be initiated promptly and contain sufficient documentation and justification to support the cost transfer that would stand the test of a formal audit.
   2. The timeliness of a cost transfer is determined based upon a 90-day threshold period, calculated from the last day of the month in which the charge first posted in the general ledger.
   3. Untimely cost transfers occurring after the 90-day threshold period must document answers to a series of questions to justify the appropriateness of the transfer. These questions include:
   4. Cost transfers to remove charges that do not meet the cost principles outlined in Uniform Guidance 2 CFR Part §200, Subpart E must be completed regardless of timing.
6. Supporting Documentation
   1. Cost transfer documentation must indicate that the PI has approved or directed the transaction.
   2. Adequate documentation related to the cost transfer and original expense must be attached to the journal voucher and kept on file within the department until the record retention requirement has been satisfied.
7. Cost Transfer Approvals and Authorization
   1. All cost transfers will be routed electronically to an administrator other than the originator for approval, and the PI will be copied.
   2. Untimely cost transfers will be routed electronically for Research Office review and approval.
8. PI/Department Responsibilities
   1. Review sponsored research projects on a regular basis (at least monthly) to ensure that all expenditures charged are correct and appropriate.
   2. Submit and approve cost transfers in compliance with university policy and procedures.
   3. Retain all supporting documentation of the cost transfer in accordance with applicable records retention regulations and University policies.
   4. Ensure that all personnel engaged in financial administration of federally-funded sponsored projects are familiar with the University cost transfer policy.
9. Research Office Responsibilities
   1. Develop and implement cost transfer procedures in accordance with the regulations outlined in Uniform Guidance 2 CFR 200, Subpart E – Cost Principles.
   2. Assist in the interpretation and implementation of the cost transfer policy.
   3. Provide final approval for untimely cost transfers.
   4. Periodically review cost transfers to ensure compliance with University and federal regulations.

Related Links

General Counsel Page for this Policy

The complete policy and more can be found on the General Counsel’s web site.

Subaward Management Policy

1. SCOPE OF POLICY
   This policy sets forth requirements for issuance and administration of outgoing subawards and applies to all departments, faculty, and staff involved in externally sponsored research at the University of Delaware (UD).
2. DEFINITIONS
   1. Sponsor or Sponsoring Agency or Prime Sponsor – An external entity responsible for providing project funding to UD under a formal award agreement. Also known as Prime Sponsor.
   2. Sponsored Award or Prime Award – A formal award agreement issuing funding from an external sponsoring agency to UD to achieve specified project goals. Also known as Prime Sponsored Award.
   3. Pass Through Funds – Funds originally issued to UD which are subsequently transferred to a subrecipient to implement sponsored award activities.
   4. Subrecipient – An external entity that receives pass-through funds via a subaward from UD to implement a specified portion of sponsored award activities. Also known as subawardee, subgrantee, or subcontractee.
   5. Contractor – An external entity that receives funding from UD via a procurement contract to provide goods or services related to the sponsored award. Examples of external contractors include a Consultant, Vendor, or Service Provider relationship.
   6. Subaward – A formal award agreement issuing pass through funds from UD to a subrecipient to implement a specified portion of sponsored award activities. Also known as a subagreement, subgrant, or subcontract.
   7. Procurement Contract – A formal contract agreement issued from UD to a contractor to provide specified goods or services under the prime sponsored award.
   8. Single Audit – A compliance and financial audit required of any institution receiving over $750,000 in federal funds to assure effective management and use of funds. Also known as the “A-133” audit.
   9. Authorized Institutional Official – An individual officially designated with institutional authority to legally bind UD in grants administration matters.
   10. Federal Funding Accounting and Transparency Act (FFATA) – A 2006 act of Congress that requires information on federal awards to be made available to the public via www.USASpending.gov
3. POLICY STATEMENT
   The objective of this policy is to provide guidance to Principal Investigators (PIs), Department/College Administrators, Research Office Administrators, and other responsible UD parties for issuing and administering outgoing subawards.

   Key administrative activities related to subaward management include:

   • Accurate determination of external collaborators as subrecipients or contractors.
   • Inclusion of subawards during UD proposal submissions.
   • Assessment of subrecipient risk level prior to subaward issuance or modification.
   • Incorporation of applicable monitoring requirements into subaward terms and conditions based on risk level.
   • Issuance or modification of subaward agreements in coordination with subrecipients.
   • Monitoring of programmatic and financial activities associated with the subaward.
   • Termination of a subaward via normal closeout activities or extenuating circumstances
4. POLICY STANDARDS AND PROCEDURES
   1. General Considerations
      1. UD may issue an outgoing subaward to a subrecipient to conduct a specified portion of the work performed under a sponsored award. As the prime recipient of the sponsored award, UD is obligated to undertake certain stewardship activities to ensure the subrecipient:
         1. Possesses adequate technical expertise and potential ability to successfully perform their scope of work in alignment with the prime sponsored award objectives.
         2. Proposes an appropriate budget for their applicable scope of work.
         3. Manages funds and meets performance goals stipulated by the prime sponsored award.
         4. Complies with governing laws, regulations, and special terms and conditions associated with the prime award; this includes compliance with federal regulations set forth per Uniform Guidance including 2 CFR 200.330 as applicable for federal and federal flow-through awards.
      2. UD PIs are responsible for initiating the request for UD engagement with a subrecipient. This request typically occurs during proposal submission, but may also occur during the course of the award:
         1. Upon funding of a proposal, the prime sponsored award issued to UD typically includes specific authorization and an explicit budget for any proposed subawards.
         2. Occasionally, the need for a subaward develops after a sponsored award has already been issued to UD. These instances may require UD to obtain prior written approval from the sponsor to issue a subaward; please confirm prior approval requirements with the Research Office.
   2. Subrecipient v. Contractor Determination
      1. The appropriate classification of a subaward or other procurement action at the time a sponsored award is proposed and funded is essential for ensuring:
         1. Proper budgeting and accounting for related costs.
         2. Adherence to applicable compliance requirements for subrecipients versus contractors.
      2. UD utilizes a standard “Provider Category Determination Worksheet” (PCDW) to correctly classify UD’s substantive relationship with an external collaborator as that of a subrecipient or contractor.

          

         Subrecipient Characteristics:	Contractor Characteristics:
         Performs substantive programmatic work related to the sponsored award Bears responsibility for programmatic decision making Is accountable for measurable performance requirements Must adhere to compliance requirements specified by the sponsored award	Provides goods or services which are ancillary to the sponsored award operations Normally operates in a competitive environment Provides similar goods or services to many different purchasers Is not subject to compliance requirements of the sponsored award
         Use of Judgement: All characteristics listed above may not be present in all cases. UD will use its judgment in correctly classifying the relationship between UD and an external entity.

      3. Key considerations utilized for subrecipient versus contractor determination are outlined below:
      4. In determining whether an agreement between UD and an external entity casts the latter as a subrecipient or a contractor, the substance of the relationship is more important than the form of the agreement. As such, UD must use judgment in classifying each agreement as a subaward or a procurement contract, as certain characteristics outlined above may not be present in all cases.
   3. Subaward Issuance and Modifications
      1. The Research Office prepares, issues and administers subawards jointly with the UD PI and his/her unit administration to ensure subrecipient compliance with the prime sponsored award.
      2. Subawards may only be issued, modified and executed on behalf of the University by an authorized institutional official with delegated signature authority.
         1. A UD PI or other unauthorized individual may not approve a subrecipient to begin working without a fully-executed subaward from UD. Subrecipients that prematurely commence work do so at their own risk, and have no assurance of payment from UD.
         2. UD is a member of the Federal Demonstration Partnership (FDP) and requires utilization of standard FDP templates to expedite subaward execution when possible.
         3. Subaward modifications are executed by UD in accordance with any modifications to the prime sponsored award (e.g. incremental funding or renewal), or as a result of actions required due to subrecipient monitoring (e.g. changes to a subaward’s terms and conditions). Subaward modifications are normally issued annually to coincide with routine monitoring activities
      3. Components below must be completed prior to UD issuance or modification of a subaward:
         1. Establishment of the prime sponsored award in UD’s financial system.
         2. Establishment of the subaward purchase order requisition or amendment.
         3. Confirmation that subrecipients receiving federal or federal flow through funds have a DUNS# and an active SAM registration.
         4. Completion of subrecipient risk assessment or monitoring activities per subsequent sections of this policy. UD reserves the right not to enter into a subaward or terminate an existing relationship wherein the risk of engagement is deemed too high or excessive.
      4. Key items outlined in the subaward agreement issued by UD should include:
         1. Payment Terms
            1. Subawards are typically issued on a cost-reimbursement basis by UD.
            2. UD will issue a fixed price subaward with a predetermined payment schedule under limited circumstances. Fixed price awards typically:
               1. Require prior written approval (or waiver thereof) by the sponsor.
               2. Require a specific project scope in alignment with prime sponsored award objectives, wherein subrecipient accountability is based on performance and results.
               3. May not exceed $150,000 funds wherein:
                  1. The fixed funding amount is based on adequate cost, historical, or unit pricing data used to reasonably estimate actual costs.
                  2. Payments are based on meeting requirements of the sponsored award.
                  3. Mandatory cost sharing or match is not required by the sponsored award.
                  4. The subrecipient will realize no increment above actual costs.
               4. Must specify and utilize one of the following payment methods:
                  1. Payments made for a set of specific milestones agreed upon prior to work performed and set forth in the prime sponsored award.
                  2. Payments made on a per-unit basis at defined prices agreed upon prior to work performed and set forth in the prime sponsored award.
                  3. Lump sum payment made at time of award completion.
         2. Authorized Funding Amount and Period of Performance
            1. Subawards will be issued and modified in alignment with their allotted budget amount and timeline authorized per UD’s prime sponsored award.
            2. Subawards are normally issued annually to coincide with routine monitoring activities. Only in unique situations will a subaward be issued in increments greater than one year.
         3. Facilities and Administrative Costs (F&A)
            1. UD personnel may not require/suggest subrecipients forego their entitled F&A.
            2. UD will issue a subaward using the subrecipient’s federally negotiated F&A rate except under circumstances specified below:
               1. UD and subrecipients are required to limit total F&A to a cap specified per written sponsor policy or the funding opportunity.
               2. If the subrecipient does not have a federally negotiated F&A rate, a de miniumus 10% F&A rate will be used on the subaward’s Modified Total Direct Costs (MTDC) per Uniform Guidance 2 CFR 200.414. Subrecipients which have had a federally negotiated F&A rate in the past are not eligible for the de minimus 10% F&A rate.
   4. Subrecipient Risk Assessment and Monitoring
      1. It is UD’s policy to complete a risk assessment prior to issuing a subaward/amendment, no less than annually. This ensures that the most appropriate subrecipient monitoring plan is:
         1. Developed based on a standardized process,
         2. Communicated to the subrecipient, and
         3. Documented in the terms of the subaward
      2. UD’s risk assessment categorizes a subrecipient as “Low”, “Moderate” or “High” risk based on a predetermined set of risk factors. Typical implications for subrecipient monitoring based on their assigned risk level are outlined below:

          

         Risk Level	Subrecipient Monitoring Guidelines
         Low Risk	Check all subrecipient invoices to confirm they: Adhere to the required format as specified in the subaward agreement which requires inclusion of the following: UD Purchase Order Number UD Award Number Invoice line items per the approved subaward budget Current and Cumulative Totals by budget category (including Cost Share) A signed certification statement as to the accuracy and appropriateness of the charges from an authorized Subrecipient Institutional Official Are within the allowable subaward project period start and end dates Contain F&A charges calculated in accordance with the subrecipient’s federally negotiated F&A rate agreement Contain billed amounts which appear reasonable based on technical progress towards project goals Do not contain any unallowable charges such as alcohol, meals, postage, office supplies or other unallowable items except where specifically authorized as per the subaward agreement For Final Invoices, invoices are clearly marked “FINAL” and accompanied by the Subaward Closeout Form. Note: A subrecipient invoice will not be approved for payment until all errors, discrepancies, or questionable items have been adequately and fully resolved.
         Moderate Risk	Incorporate additional requirements dependent on UD management decision: Required copies of supporting/backup documentation for subaward invoice charges such as: Payroll records to support invoice personnel charges Copies of receipts for specific charges (travel, supplies, equipment, etc.) Copies of consultant hourly rates and time charged Transactional detail from the subrecipient’s accounting system of record More frequent submission of subrecipient invoices and technical reports Requirement to align subrecipient invoice payments to technical progress
         High Risk	Incorporate additional requirements dependent on UD management decision: Mandated regularly scheduled conference calls with the UD PI and subrecipient institutional representative Financial Desk Audits Site visits, both technical and financial

      3. It is UD’s responsibility to ensure that all agreed-upon monitoring activities occur and that the results of the risk assessment are updated accordingly.
         1. UD may adjust a subrecipient’s assigned risk level and applicable monitoring activities throughout the course of a sponsored award.
            1. The PI is responsible for monitoring the technical progress of the subrecipient to ensure their performance is aligned with objectives outlined in the subaward and the prime sponsored award, including:
               1. Advancing toward the completion of programmatic goals.
               2. Submitting accurate and timely invoices and technical reports as required.
         2. One or more of the following actions may be taken by UD for subrecipients deemed noncompliant as a result of subaward monitoring activities:
            1. Temporarily withholding cash payments pending correction of the deficiency,
            2. Denying both use of funds and any applicable matching credit for all or part of the cost of the activity or action,
            3. Wholly or partly suspending or terminating the subaward, and/or
            4. Taking other remedies that may be legally available.
            5. Note: In most cases, noncompliance must be documented to support above actions.
   5. Subaward Closeout and Termination
      1. Normal closeout and termination of a subaward occurs upon expiration of the subaward period of performance. Action should be taken to complete key activities in a timely manner, including:
         1. Confirmation by the UD PI that all subaward deliverables have been met.
         2. UD receipt of a final subaward invoice and associated closeout documents:
            1. The final subaward invoice must be clearly marked “FINAL” with certification statements signed by the Subrecipient Institutional Official
            2. UD requires the subrecipient’s final invoice be accompanied by a completed “Subaward Closeout Form” signed by the Subrecipient Institutional Official and the Subrecipient PI prior to releasing payment. This form contains:
               1. Confirmation that the subrecipient sent a final invoice to UD
               2. Confirmation of the final subaward expenditures.
               3. Amount of required cost share.
               4. Completion of all final technical/patent/equipment reports and deliverables.
            3. UD typically incorporates a 60-day grace period from the subaward end date for the receipt of the subrecipient’s final invoice.
            4. If UD does not obtain the subrecipient’s final invoice in a timely manner, UD reserves the right to treat the last invoice received from the subrecipient as the final invoice.
         3. Closeout of the subaward purchase order via a Purchase Order Amendment Webform after the final subaward invoice is paid.
      2. Early closeout and termination of a subaward occurs when the subaward is terminated prior to the original subaward end date specified in the subaward agreement.
         1. An agreement may need to be terminated early at the request of the sponsor, UD, or by mutual agreement between UD and the subrecipient.
            1. The UD PI may consider termination due to factors related to suboptimal subrecipient performance towards project milestones, services, or objectives specified in the subaward agreement. Any UD PI contemplating early termination of a subaward should immediately contact the Subaward Team within Research Office for appropriate action.
         2. Sponsor regulations and subaward specific terms and conditions detail the steps needed to process an early termination of a fully-executed subaward agreement.
            1. UD typically incorporates a clause into the subaward agreement outlining UD’s right to terminate a subaward within 30-days of official written notice to the subrecipient.
               1. A “Stop Work Order” is a formal notification to the subrecipient to discontinue all work on a subaward. UD will issue a “Stop Work Order” to a subrecipient in the rare instance when all other remediation means have been unsuccessful.
            2. The Research Office will work with the PI and their unit administration to ensure all required termination actions and documentation is completed.
   6. Roles and Responsibilities
      1. Successful administration of subawards relies heavily on the involvement and coordination of multiple parties across campus including the UD PI, unit administration, the Research Office, and others. The table below provides an overview of applicable roles and responsibilities for subawards:

          

UD Individual Development Plan (IDP)

University of Delaware IDP policy
The University of Delaware requires Individual Development Plans (IDPs) to be completed for graduate students and postdocs funded by NIH (regardless of funding mechanism) each year. The use of IDPs for all graduate students and postdocs is encouraged as a means for professional development and career planning. Additionally, other funding agencies are beginning to request IDPs.

Reporting
PIs of NIH grants must report on the use of IDPs in their annual Research Progress Performance Report (RPPR) in Section B. Accomplishments, Question B.4. PIs do not need to include actual IDPs; they need to document that graduate students and postdocs funded by the award use IDPs and discuss them with their mentors on an annual basis. Below is suggested wording for inclusion in the RPPR. PIs should modify the text as needed to accurately reflect their activities in encouraging their trainees to develop and utilize IDPs.

Related Links

AAAS “myIDP” Individual Development Planning Tool
UD IDP Assessment Form