Award Acceptance / Award Obligation Set up Process
Once a new award or an award increment comes into Northeastern, NU-RES undertakes an award acceptance process to ensure that all the relevant regulatory and fiduciary obligations met the specifications of the proposal, as well as funding agency expectations. Northeastern calls this the Award Obligation Set up (AOS) Process.
Based on the funding agency requirements, NU-RES will need to verify several key pieces of information:
Budget
A detailed budget is required to finalize the account setup and subsequent updates. Please use the budget template provided in the “Helpful Links” list. NU-RES will accept other budget templates, however, complete personnel details (name, role, appointment type, institutional base salary, level of commitment, salary requested and corresponding fringe benefit rate) are required.
Conflict of Interest
The NU-RES conflict of interest review is comprised of three parts, which are driven by funding agency conflict of interest requirements and Northeastern policy:
- Investigator Determination Form: Northeastern is required to confirm which individuals engaged in the project are considered “Investigators,” responsible for the design, conduct, or reporting of the research. “Responsible for” is the operative phrase and indicates that the individual exercises control over their activities. For example, a student reporting the research independently would meet the definition of Investigator. However, if the student is working as part of a team supervised by a faculty member, they would not meet the definition of Investigator.
- Verification of outside activities disclosure: NU-RES must verify that Northeastern has an outside activities disclosure on file for each Investigator.
- Training: This requirement only applies to awards funded by a Public Health Services (PHS) federal agency or other funding agencies that adhere to the PHS Financial Conflict of Interest (FCOI) guidelines (including subawards). Investigators participating in research under a project subject to the PHS FCOI regulations are required to complete the CITI FCOI training module. NU-RES completes compliance checks of all awards to ensure CITI training is complete and up-to-date. If an Investigator does not have a current CITI training completed at the time a notice of award is received, they will have to complete the training, and email NU-RES@northeastern.edu upon completion to ensure timely processing of the award obligation.
Institutional Approvals
NU-RES requires confirmation that all institutional approvals associated with the project have been obtained. Please provide NU-RES with any approval letters related to the award, especially those related to:
- IACUC: Please see the DLAM website to submit a request for an IACUC approval.
- IBC: Please see the IBC website to apply for an IBC registration.
- IRB: Please see the HSRP website to request a Human Subjects Determination review and/or submit a request for an IRB approval.
- UAS: Please see the UAS Committee website to submit a request for an UAS approval.
Once all documents have been verified an AOS sheet will be prepared summarizing the award and a final award package will be compiled. The PI and their designated administrators will receive the final award package upon completion of the AOS review.
How to Change an Org and/or Credit Split
The college(s) should provide the credit split and budget breakdowns to NU-RES at the time of award set up. NU-RES recommends that the college review the organizations (orgs) and credit splits associated with each research project on an annual basis (at minimum). Any faculty members that have left Northeastern or ceased working on the project should have their credits re-assigned to someone else in the org/department/college, as appropriate.
If a faculty member has left Northeastern but is still working on the project, NU-RES recommends that they are removed from the credit split. Their participation and effort will be captured via any subaward or consulting agreement that may be issued to them.
Should the college(s) need to amend a credit split or org/department, please complete a Transaction Form and have it approved by any impacted department chairs and PIs. In the event that the signature of multiple PIs and/or chairs is required, please be advised that the Transaction Form does not have additional signature blocks, thus an email approval from the relevant department chairs and PIs are sufficient.
Completed Transaction Forms should be routed to nu-res@northeastern.edu. NU-RES will update the database, typically within 10 business days.
Please note that the specific award obligation components listed above are the most common elements of the AOS review. Specific grants or contracts may include additional requirements, not listed above. In such cases, NU-RES will work with PIs on a case-by-case basis to identify and verify any award-specific requirements.
Administrative Award Management & Prior Approvals
After an award is set up, NU-RES encourages pro-active award management to ensure that the project’s programmatic progress, budget and other details on file with the funding agency are consistent with the work actually being performed.
Award terms and conditions vary widely and may have multiple interpretations. For questions on the interpretation of award terms, including questions of allowability, please confer with the relevant Grant Officer. If you are not sure, send a note to the nu-res@northeastern.edu mailbox and the request will be triaged within one business day.
Prior approvals:
It is important Northeastern requests prior approval, in a timely fashion, from the funding agency’s authorized official when required by the terms and conditions. NU-RES recommends requesting prior approval at least 30 days prior to the change effective date, if possible.
This minimizes the risk that the PI or college will have to pay for expenses denied by a funding agency because they did not approve of a change. It also strengthens Northeastern’s reputation with the funding agency as a strong and effective steward of funding.
Prior approvals are needed when the award made to Northeastern requires changes to key aspects of a project’s budget, personnel or scope of work. Some of the most frequent types of prior approvals are outlined below.
Note: this list is not intended to be exhaustive or complete; the PI and the college should be aware of the award’s specific terms and conditions. The PI and college are responsible for initiating prior approvals based on the award requirements.
- Carryover:some awards restrict the use of funds across budget periods. Northeastern must make a formal request to bring the funds from a prior budget period into the current period.
- Change in personnel: many funding agencies require Northeastern to request prior approval to remove key personnel from a project. Typically, key personnel are named on the Notice of Award (NOA). Northeastern should always seek prior approval if the PI for the project will change.
- Change in scope: funding agencies provide awards based on a specific proposal and expect to see the project they agreed to fund completed as proposed. If the scope of the project needs to change for any reason, including that the science is not working out as planned, the funding agency must approve that change in approach/scope. Keep in mind that some changes in scope may impact the budget.
- Equipment:If equipment not contemplated in the proposal will be purchased, review the award terms and conditions to verify if equipment may be purchased and if so, what types of equipment require prior approval. Many funding agencies consider the addition of a piece of equipment to indicate a change in scope.
- Rebudget: Many funding agencies do permit Northeastern to forego prior approval for minor rebudgets (i.e. increasing personnel costs and spending less on supplies), as long as that change is not part of a change in scope. Most funding agencies require prior approval for rebudgets in excess of 25% of the budget. Please review the specific award terms and conditions as many non-federal funding agencies have very varied approaches to rebudgeting.
- Subawards: may funding agencies require prior approval to add or remove a subrecipient.
No Cost Extensions (NCE): allow the last budget period to be extended by a year. This is often done complete some element of the project, including the reporting of results. NCEs may not be requested to spend down a remaining balance.
Submit requests for prior approvals using a Transaction Form to nu-res@northeastern.edu. The How-to Guide provides additional information on completing the form.
NU-RES is always available to support the PI and college in their analysis of an award’s requirements. Please contact your Grant Officer for assistance.
