A. Project Oversight and Account Establishment
While Washington Sea Grant (WSG) receives funding from a number of federal and state sources, most of the fiscal resources that support its research program come from NOAA through grants to the University of Washington (UW). For this reason, all WSG fund recipients, including subawardees, are subject to federal cost accounting requirements and NOAA standard award terms and conditions. Each research project principal investigator is responsible for understanding and adhering to these terms, conditions, and requirements, as well as those of the host institution regarding allowable use of project funds.
As the principal investigator, you are accountable for the project’s overall progress, administration, and budget. You are also responsible for ensuring that the project meets any applicable animal care or human subject requirements and for obtaining necessary approvals from your institution’s IACUC or IRB office prior to the initiation of the project. Copies of approvals, including modifications to existing protocols or approvals, must be submitted to WSG for their award records.
Project funds generally are issued annually; however, release will depend on the timing and amount of funds WSG receives from NOAA and will be based on awarded budgets and timelines. WSG reviews all project budgets, cost share, and progress reports prior to release of continued funding. Please be proactive in communicating with the Director about any issues that may affect the progress, scope, or budget of your project.
For projects with a UW principal investigator, the UW’s Grant and Contract Accounting office will establish a budget number according to the approved budget and award dates. For a non-UW principal investigator, the UW Office of Sponsored Programs will initiate a subaward with the investigator’s institution.
B. Multi-Investigator or Institution Projects
In cases where a project includes subawards to other institutions, or funding is split between several institutions, the principal investigator is responsible for the conduct of the project as a whole. She or he should maintain close contact with all associate and co-principal investigators to ensure that steady progress is made toward completing project objectives and that progress reports, final reports, and required financial documentation cover all portions of the project.
The principal investigator is responsible for distributing project-related correspondence (including the Letter of Award and this project administration document) to any associate or co-principal investigators. All project-related requests should be endorsed and submitted to WSG by the principal investigator.
Projects funded among multiple state Sea Grant programs may have special award requirements, which will be determined on an individual project basis.
C. Cost Share
Federal requirements stipulate that projects must document and report expenditures committed as cost-share or matching funds as they occur throughout the year. WSG expects this will be done quarterly. For projects located at UW, faculty effort certification is processed online and reported to the UW Office of Management Accounting and Analysis; other types of cost share are submitted to UW Grant and Contract Accounting.
Cost share must be met through the use of non-federal sources and is subject to the same compliance and audit requirements as direct charges to federal awards. As principal investigator, you are responsible for ensuring compliance and accurate recordkeeping for all funds or transactions reported as cost share on a WSG project. The WSG Administrator will work with you to address any cost-share questions.
Cost-share documentation must be up-to-date before WSG considers grant action on the project, including transfer of subsequent funding or extension requests. This requirement may also extend to other WSG proposals or activities for which the principal investigator is responsible. If the cost-share commitment in the approved project budget is not met, WSG may be required to reduce the federal share of the award proportionately and, if necessary, retroactively.
D. Modification of Project Scope and Personnel
The approved proposal, timeline, and agreed-upon responses to reviews constitute the scope of work for WSG projects. Written approval from the WSG Director is required before changes are made to this scope of work (including subawards) or to senior personnel status (including grantee organization, percentage time, and sabbaticals or other leaves of absence).
To request a project modification, a principal investigator must contact the WSG Director and provide a written explanation that justifies the proposed change and the impact on the project’s progress and results. If replacement of senior personnel is proposed, include a biographical sketch and a description of the work they will be performing. In some situations, WSG may need to contact the National Sea Grant Office for concurrence.
E. Budget Management
Prior approval from the WSG Director is also required for significant budget modifications. To obtain an approval, the principal investigator should submit the following information:
- WSG project number and project title
- UW budget number or subaward number
- Details of, and a justification for, the proposed changes by budget category (salaries, supplies, equipment, travel, other, indirect costs)
- A comparison of the original and new budget by line item in a spreadsheet format
Principal investigators must ensure proper oversight and handling of their project award. Deficits (including cost share) or project cost overruns are the responsibility of the principal investigator’s department or organization and cannot be absorbed by WSG. All deficits must be cleared prior to the expiration of the project.
Principal investigators must request prior approval from WSG for any permanent equipment purchase that was not included in the approved budget for the project. If the unit cost is in excess of $5,000, WSG is required to obtain prior approval from NOAA. Classification as “permanent equipment” may vary among institutions. For projects located at UW, the term applies to equipment having a value equal to or in excess of $2,000, and a life expectancy of one year or longer. Permanent equipment purchased with WSG funds must be managed and tracked through appropriate property inventory control systems in accordance with the practices of the investigator’s institution. Investigators must have prior written approval from WSG to make any permanent equipment purchases within 90 days of the expiration date of the project award.
Purchase, rental, or repair of general-purchase equipment requires prior approval regardless of the amount of the expenditure. General-purpose equipment includes any item that is usable for activities of the institution other than research (e.g., office equipment and furnishings, computer or reproduction equipment, refrigerators, motor vehicles).
Expendable equipment purchases of less than $2,000 per unit are considered supply items, and should be processed and billed as such.
G. Foreign Travel
Principal investigators must request prior approval from WSG for any foreign travel that was not itemized (location, date of trip, estimated cost identifying airfare, and per diem) in the original NOAA-approved project proposal and budget. As foreign travel requires NOAA approval, WSG will need a written request at least 60 days PRIOR to the departure date, with justification that provides the following:
- Project title and principal investigator
- Traveler name
- Travel dates
- Origin and destination of the travel
- A detailed itinerary with the name of the air carrier and flight number for each leg of the trip
- Completed documentation for a Fly America Act waiver (to be discussed with WSG prior to submission of request) if no U.S. carriers are available and a foreign carrier is to be used for any portion of a trip. The Fly America Act mandates that all foreign travel funded by federal dollars use U.S.-certificated air carriers unless a reasonable exception applies. Grant funds cannot be used to reimburse any travel expenses that are not in compliance with the law.
Principle Investigators must request approval from WSG prior to generating any subawards (excluding those for standard goods or services) that were not described as part of the approved proposal. The request should describe the proposed scope of work to be accomplished by the subawardee, how the subawardee was selected, why a subaward is the best course of action, the name and expertise of the subawardee, the amount of funds to be awarded, a detailed budget and budget justification, and the impact on the overall project budget.
I. No-Cost Extensions
Investigators are expected to adhere to the project’s approved timeline and to complete the project by the award end date. When circumstances prevent this, the principle investigator must submit a written request to the WSG Director for an extension without additional funds (no-cost extension). Projects cannot be extended merely to allow recipients to spend remaining funds. Extensions may be one-time or may be approved incrementally. In most cases, an extension should not exceed the original project end date by more than one year. The WSG Director’s ability to approve a request for a no-cost extension may be constrained by conditions and limitations established in WSG’s parent award.
Requests should be submitted at least 30 days before the project expiration date. Prior to submission, the principal investigator should verify that all cost-share documentation and required reports are up-to-date. To request a no-cost extension, please send an email with the following information to firstname.lastname@example.org:
- WSG project number and project title
- UW budget number or subaward number
- Current and requested end dates
- One or two paragraphs that:
- summarize project progress to date
- detail the reasons for the requested extension
- outline expected outcomes the extension will support, any new project directions, and any impact on the project objectives
J. Other Federal Requirements
In addition to the standard cost principles and regulations affecting institutions receiving federal funds (including applicable OMB circulars and Department of Commerce Financial Assistance Standard Terms and Conditions), investigators and their institutions are reminded of the following requirements:
- Expending federal (WSG) or non-federal (cost-share) funds or providing in-kind goods and services for the purposes of providing transportation, travel, and any other expenses for any federal employee or agency is prohibited.
- Neither WSG funds nor funds proposed as cost share for WSG-supported projects may be used for constructing or purchasing a dock, building, vessel, or vehicle, nor any renovating or altering an existing structure.
- Food purchases are not allowed using WSG funds; meeting costs and catering services, membership dues, and subscriptions are not allowable unless specifically requested in the approved budget justification.