There are usually two types of reporting to sponsoring/funding agencies: Financial Reports and Project Reports.

Financial Reports: These reports are written by Financial Operations. Depending on grant agency reporting requirements, the report may be submitted directly by Financial Operations to the sponsoring/funding agency or submitted through the Project Principal Investigator.

Project Reports: These reports are written by the Project Principal Investigator. Examples of such reports are:

• Quarterly Project Report
• Half Year Project Report
• Annual Project Report
• Project End Report
• Project Assessment Report
• Project Update Report
• Project Outcomes Report
• Other Reports

Different sponsoring/funding agencies have different report requirements and submission deadlines. It is the responsibility of the Principal investigator to understand what reports are required, when they are required, and how they are to be submitted. If help is required in understanding sponsoring/funding agency requirements or in finalizing the report, please contact R&GA.

The Principal Investigator (PI) is considered the project manager of the grant awarded project and is entirely responsible for managing the project. The PI has programmatic, Administrative/Fiscal, and Compliance Responsibilities. Some of these responsibilities are:

Programmatic Responsibilities

• Diligently pursues project aims.
• Manages project personnel (hire, fire) keeping in mind the best interest for the project and the institute.
• Initiates required project changes through proper approval processes.
• Maintains and retains project data and materials for the duration required by the project.
• Completes and submits project reports on-time as defined by RMU and/or sponsoring/funding agency.

Administrative/Fiscal Responsibilities

• Satisfies regulatory research requirements.
• Discloses conflicts of interest when required.
• Ensures scientific integrity of project.
• Ensures accurate and timely effort reporting for project personnel. This includes completing the Payment Request Form and Payroll Authorizations.
• Assures expenses incurred are allowable, reasonable, and allocable to project.
• Bears ultimate responsibility for monitoring budget versus actual expenses and insuring that costs do not exceed the approved budget.

Compliance Responsibilities

• Adheres to protocols and policies for research subjects, and notifies the IRB if changes are made to protocols.
• Meets continuing IRB protocol review requirements and assists with inspections.
• Adheres to chemical, biological, physical and radiation safety requirements, and notifies the appropriate office if accidents occur.
• Takes responsibility for adherence to record retention policy for all financial and scientific documentation.
• Is compliant with RMU’s Financial Conflict of Interest (FCOI) policy.
• Takes responsibility for cooperating in the audit process, whether internal or external audit staff is involved.

If assistance is required in understanding or implementing the responsibilities, the PI should contact R&GA.

Overview
Whether on a professional level or personally, Robert Morris University (“University”) believes that great universities change lives. The University encourages faculty, staff and students to engage in research and grant activities involving grant agencies and collaborations. However, the interests and commitments can be complex and do not always coincide. Every person in the Robert Morris community is expected to act in the best interest of the University and refrain from letting significant financial interests (SFI) interfere with his/her duties. The University recognizes the benefit of engagement with federal, industry and non-profit sectors and is committed to ensuring that these relationships are conducted properly and consistently.

Purpose
The purpose of this policy is to comply with federal regulations regarding financial conflicts of interest (FCOI). This policy has been created to identify and address financial conflicts of interest in research and grant activities. This document provides guidelines to maintain truthfulness and abide by the highest ethical standards regarding financial conflicts of interest in research and grant activities. This policy is meant to increase the awareness of faculty, staff, and students of the potential for conflicts of interest and inform them on how these conflicts of interests can be avoided or properly managed to uphold the highest levels of integrity.

Scope
This policy applies to all grant funds, including anyone requesting funding or working on a grant funded by federal Public Health Service (“PHS”) agencies or the National Science Foundation (“NSF”). The University’s Policy of Ethical Practice shall govern all other conflicts of interest and their disclosures. Any conflict between this Policy and the Policy of Ethical Practice shall be resolved in favor of the more stringent requirement.

• R&G FCOI Policy

If assistance is required in understanding R&G FCOI, please contact R&GA.

An Administrative/Fiscal responsibility of a grant Principal Investigator (PI) is to ensure accurate and timely effort reporting for project personnel. This includes completing the Payment Request Form and Payroll Authorization.

To ensure project personnel is paid in a timely manner the PI must 

• Complete the Payment Request Form by the 5th of the proposed payroll month. Complete all known fields of the form. 
• Send the completed form to Julie DeVuono via inter office to Revere Center or email to devuono@rmu.edu

Once received and approved the form will go to Human Resources (HR) where a Payroll Authorization (PA) form will be generated. This form will be sent directly to the PI for authorization. The PI is then required to forward the authorized form to his/her next level supervisor. If the form is received by the payroll cutoff date payment will be made that month otherwise it will be deferred to the following month.

• Employee Compensation Payment: Grants/Awards
• Grant Funded Payment Request Form

If assistance is required please contact Julie DeVuono, Financial Operations at 412-397-5265 or R&GA at 412-397-4023.

To ensure the Principal Investigator (PI) and/or the institute is compliant with the policies of the sponsoring/funding agency, the Agency at any time can contact the institute to inform their intention to carry out an award audit. At our institute, the point of contact for this audit is Financial Operations. However, depending on the issue, the PI may also be contacted. During the Audit, the PI is requested to support the process by providing full cooperation in a professional manner. It is also important that the PI keep all documents relevant to the project intact and secure until two years after the project is completed. 

The grant audit may include but not limited to:

• Activities allowed or not allowed
• Allowable costs and cost principles
• Cash management
• Program income
• Programmatic performance
• Sub-recipient monitoring

These concerns may differ from agency to agency. The PI is requested to read grant agency documents and contact the grant agency if necessary before commencing the project.

If assistance is required, please contact Julie DeVuono, Financial Operations at 412-397-5265 or R&GA at 412-397-4023.

Awards are considered completed on the date on which the award expires or terminates. At that time either all work is complete or incomplete. If, at the end of the project period, the Principal Investigator has not secured a renewal, supplement, or no-cost extension, award closeout must be conducted. 

The award closeout phase is considered the final phase in the grant lifecycle. The closeout phase ensures that all administrative actions and required work have been completed by the recipient institution. Closeout procedures check to make sure that awardees have met all financial and reporting obligations, such as submitting final financial and project reports and returning any unspent or unobligated funds (if applicable).

Note: It is the responsibility of the PI to check the award document for all pertinent details about closeout procedures and dates. 

Timeliness is important when closing out an award to assure:

• Full compliance with the terms and conditions of the award
• Sound award management
• Collection of all monetary reimbursement for costs incurred
• Maintaining RMU’s excellent track record with the grant agency.

If not able to comply with the established close-out timeline, awardees should contact R&GA.

Final Reports

The University and the PI have an obligation to close all sponsored projects by submitting final financial, project reports, and other reports that the grant agency may require. These submissions have to be done in a manner consistent with the terms and conditions of the award. Depending on the grant agency policies, the necessary closing procedures may vary. 

Records Retention

Recipient institution must retain award records for a period of three years from the date the Final Financial Report was submitted.

• Grant Agencies may choose to conduct audits during the three-year period. If an audit is conducted, award records must be kept for a period of three years from the time at which any audit issues were resolved.
• Awardees should also take into consideration any retention requirements their institution maintains; if their institution’s retention period is longer, the federal requirement of three years does not supersede.

Final Obligations

Awardees should be aware of their continued obligations to the award terms and conditions after a grant is closed out:

• Closeout does not change the awardee’s obligation to report and return any funds later acquired through refunds, corrections, or determined to be due as the result of an audit.
• Closeout does not automatically cancel any requirements for property accountability, record retention, or financial accountability.
• Awardees must ensure all funds are obligated within the period of performance of the grant and that they are liquidated within 90 days after the termination date.
• Awardees can draw down funds for up to 90 days after the termination date.
• The requirement to retain records is not affected by closeout, nor is the sponsor's right to audit records. University must be accountable for property, royalties and program income. 

Authorized Official Signature

Some sponsors may require that final reports be signed by an Authorized Official of the University. In these cases, the report should be sent to R&GA for signature.

At RMU the PI, Financial Operations, and if necessary R&GA will have to work together to ensure projects are properly closed.