Policies & Compliance
- Research Handbook
- 1. Roles & Responsibilities
- 2. Standards for Conduct of Research
- 3. Overview of Sponsored Projects Administration
- 4. Funding Sources & Opportunities
- 5. Proposal Development
- 6. Budget Development
- 7. Procedures for the Submission of Proposals
- 8. Award Acceptance
- 9. Award Management
- 10. Research Related Regulations, Policies & Procedures
- 11. Other Conduct of Research Issues
- 12. Acronyms & Definitions
- 13. Glossary
- Procedure Library
- Regulations Library
- Export Controls
Award Management
9.8 Reporting Responsibility
Generally, grants, contracts, cooperative agreements and other funding mechanisms require regular reporting of the progress of the project through periodic financial and technical reports. The format, frequency, and depth and breadth of the reporting are determined by the sponsors.
See also Report in the Grant Life Cycle.
9.8.1 Interim Progress Reports
The PI is responsible for submitting interim progress reports to the sponsor within the specified timeframe and format indicated by the sponsor. If no format is indicated, the PI is advised to use a standard format that addresses the following project management concerns:
- A review of the accomplishments to-date as compared with schedule and objectives as outlined in the original proposal
- A review of the challenges faced by the project in attempting to meet the schedule and objectives as outlined in the original proposal
- Supporting statistical data or documentation
- Management activities, such as documentation or materials produced, personnel issues, etc.
9.8.2 Project Close-Out
Projects may require some or all of the following reporting: final technical, final financial, patent and invention, and property inventory for both purchased and sponsor supplied equipment. A closeout may also require the submission of a final invoice and a "Contractor's Release." Information regarding final reports can be found on the Project Information Sheet, in the award document or contract, and/or in the sponsoring agency's guidelines.
The PI should see Closeout in the Grant Life Cycle and consult OSP prior to the end of a project for reporting requirements, report distribution and required delivery dates. After the project has ended the entire project file, including accounting records subject to audit, is archived for the period required by the award. A project must be completed at the end of the award period if the University is to receive complete reimbursement.
See also the Closing Out an Award Overview Procedure.
9.8.2.1 Final Technical Report and Other Deliverables
Upon expiration of the project, the PI is responsible for submitting the final technical report to the sponsor within the timeframe specified. Failure to submit this report in a timely manner could jeopardize future funding by the sponsor not only for the PI but also for other investigators funded by the same sponsor. A copy or confirmation of a final report should be submitted to OSP.
The PI is responsible for submission of all technical reports required under the terms of an award, as well as other agreed upon deliverables such as data, graphs or software.
Failure on the part of the PI to deliver any required technical reports to the sponsor in a timely matter may effect the collection of funds for this project and future funding from that sponsor to all Colleges of the University of Utah. In addition, the terms of many contracts provide that final payments will not be made until the required final reports have been submitted.
As a confirmation that this requirement has been fulfilled, the PI is required to provide OSP with a copy of the final technical report or, if the report is extremely large, a copy of the summary or transmittal letter and a listing of the distribution of the report.
It is also the responsibility of the PI to mark any and all material that has a proprietary status and should not be released to the general public.
9.8.2.2 Final Financial Report
The Office of Grants & Contracts Accounting is responsible for submitting any financial reports required in order to closeout the award. The expiration of an agreement usually requires a final invoice and/or final financial report from the University to the sponsor. In the final invoice, the University would request any residual funds due to the University under the award or would refund to the sponsor any excess funds not expended if the award was cost reimbursable. Any non-substantive residual funds from a fixed price contract can be moved to an operating or development activity at the Principal Investigator's request.
The PI’s department prepares fiscal reports for clinical investigations or trials.
When Grants & Contracts Accounting determines that no funds are owed to the University for expenses incurred under the award, a "Contractor's Release" signed by the Director of Sponsored Projects will be sent to the sponsor, if required. This "release" is an acknowledgment by the University that it has no further claims against the sponsor. A contractor's release is not usually required for a grant award or for most clinical studies.
9.8.2.3 Final Inventory Report and Title to Property
The sponsor's policies on title to property must be followed when closing out an award. Many sponsors request a property inventory report whether or not title to such property is retained by the University. When title is not retained at the time of acquisition, University Property Management will request title. At the request of OSP, Property Management is responsible for completing the final inventory report. The PI should assist in any property issues because delayed property issues may result in delayed payment of the final invoice by the awarding agency.
9.8.2.4 Patent and Invention Report
When required by the sponsor, the Technology & Venture Commercialization completes a final "Report of Patents or Inventions" even if the report is negative. If a patentable idea, invention or discovery is made as a result of a sponsored project, the disclosure of such must be made through TVC usually within a specified time or the University may lose rights to the invention. The PI must contact TVC as soon as it is practical to start the patent process.
9.8.3 Late Reports or Non-Reporting
If a project is not going to be completed on the agreed upon project period or the reports will be submitted to the sponsor later than anticipated, it is critical that the sponsor be informed well in advance. In some instances failure to submit timely reports will delay payment of invoices by the sponsor.
When industry sponsors a project or a contract is entered into with a federal or state entity, they generally require a project timetable, milestone chart and a list of specific deliverables. If unavoidable delays occur, the University must have a letter or contract amendment reflecting the approved change. Even the most affable relationship with a sponsor can disintegrate rapidly if the sponsor comes upon difficult financial situations or has an immediate need for the project outcomes. For this reason, any change must be in writing. While this does not insure payment, if the University pursues legal action, we are better protected.
Federal agencies are extremely aggressive about insisting on timely reporting. Industry, because most projects are time sensitive, are insistent upon final reports in a specified time. In addition to withholding future awards, both federal and state agencies and industry generally will not issue final payment on a project until reports are received.
9.8.3.1 Government Agency Policies
The following are the policies by Government Agencies for late reports on research projects.
Please review the Overdue Reporting Escalation Procedure. Federal regulations allow forcorrective actions as referenced in §200.339 Remedies for noncompliance.
- National Science Foundation (NSF)
- Suspension and eventual termination of all award actions to
- PI Withholding of new awards to University if 10 or more reports are delinquent
- Suspension of payment on existing awards
- National Institutes of Health (NIH)
- Withholding of support for eligible projects or activities for PI and Co-PI
- Withholding of support for eligible projects for University
- Department of Energy (DOE)
- Withholding of support for eligible projects for University with one delinquent report
- National Aeronautics and Space Administration (NASA) (PDF)
- Withholding of support for eligible projects for University with one delinquent report
- Office of Naval Research (ONR)
- Beginning 91 days after award expiration, the PI assigned to that award will not be eligible for new ONR awards until the reports are received
- Beginning 181 days after award expiration, the University will not be eligible for new ONR awards until the reports are received
- Department of Education (DED)
- Noncompliance jeopardizes PI's chance for future funding
- Air Force Office of Scientific Research (AFOSR)
- Place hold on final payments
- Withholding of support for eligible projects or activities for PI
- Army Research Office (ARO)
- No policy at this time
9.8.3.2 University Policies
If a PI is unable to complete a report, the department chair and/or dean become responsible to complete it.
Unless specifically approved by the sponsor or award is specifically for dissertation or thesis support, submitting a thesis or equivalent as a final technical report is inappropriate and usually not sufficient to meet reporting requirements.
If reporting is severely delinquent, OSP will notify the PI of late reports and copy the department chair and dean. If a follow-up notice is required, the Vice President for Research will notify the PI in writing, with copies to the chair and dean, that Sponsored OSP will not process additional proposals or awards until all delinquent reports have been submitted and accepted by the sponsor. In some cases, the sponsor will reject future proposals and block future funding on all projects until the required reporting is submitted and processed.
