Opening Accounts

• Temporary Accounts Procedure
  
  
• Award continuation years
  For awards with performance periods spanning more than one year, the same FAS account number will be used for all budget periods whenever possible (“multi-year accounts”). However, awards that require annual financial reports or that require sponsor prior approval to carry forward unobligated funds will be set up with a separate FAS account for each budget period.

  In cases when a separate FAS account will be set up for each budget period, a temporary account for the continuation year may be requested after the progress report has been routed. The completed/signed temporary account request form may be attached to the routing forms at the time they are circulated for signatures.

• Budgets in Multi-year accounts
  Although award project periods may span several years, funds are generally awarded incrementally on an annual basis. The account end date in FAS will reflect the entire project period. However, the account budget will reflect only the amount awarded by the sponsor thus far. The budget in FAS will be updated when the next increment of funding is awarded by the sponsor, usually annually. Often an annual progress report is required by the sponsor to trigger the award of continuation funding. If there is a need to spend the next increment of funding prior to receipt of the award for the continuation period, a temporary account request should be submitted.
  
• IMPORTANT NOTE: projects involving IRB and IACUC protocols
  FAS accounts cannot be established for projects that involve human subjects and/or vertebrate animal use until the pertinent protocols have been fully approved by the IRB and/or IACUC. However, the end date of the FAS account is not related to IRB and IACUC protocol expiration dates.

The UMB policy for the creation of an account which involves either human subjects or animal subjects requires that an active IRB or IACUC approval be in place at the time the award is processed for an account number. If it is not, in exceptional circumstances ORD may waive that requirement on a case-by-case basis.

When can the requirement for IRB/IACUC approval be waived? Under some circumstances, a project involves preliminary work, including protocol development, prior to recruitment and enrollment of human subjects or initiation of research using animals. Review of the file by ORD normally is initiated as the result of a request from the Principal Investigator or the PI’s administrator with an explanation of the special circumstances. If the special circumstances are confirmed by ORD, the award may be processed for an account number; however, the PI and administrator are notified that no expenses may be charged for human subjects research or animal research until the relevant protocol has been approved.

Multisite clinical trials: Accounts are set up only after IRB approval is obtained. The only activities supported by multisite clinical study agreements are those that involve human subjects. Therefore, regardless of other dates referenced on the contract (signature dates, etc.), the earliest possible date for the account will be the date of IRB approval.

Noncompeting continuation years of projects: ORD assumes that IRB/IACUC approval is ongoing and active, but reserves the right to request the approval document. If the approval documentation that ORD has on file clearly has expired prior to receipt/processing of the award notice, ORD requires active IRB/IACUC approval documentation.

Temporary accounts: The policy for authorization of temporary accounts with regard to IRB/IACUC approvals is the same as that for processing of awards.

Documentation available to ORD:

• ORD has electronic access to IRB documentation but only if the protocol number is provided.
  
• ORD does not have electronic access to IACUC documentation from any of the schools; therefore, upon request, the IACUC document must be provided to ORD by the PI or administrator.

Federal Regulations mandate that no research involving human subjects, including enrolling new subjects, conducting interventions, or analyzing subject-identifiable data, may be performed without ongoing IRB approval and no research involving vertebrate animals may be performed without ongoing IACUC approval. If at any time your IRB or IACUC approvals expire for the protocols associated with a project, research involving human subjects and/or vertebrate animals under the expired protocol(s) must be halted and expenses for such research may not be incurred. Failure to observe the policies and procedures governing human subjects research and research with vertebrate animals at UMB will be considered serious misconduct subject to sanctions including possible termination of faculty appointment.

Closing Accounts

• Finalizing Expenditures
  
• Final Invoice ® In addition to reconciling expenditures, ensure that the Sponsor has been invoiced in accordance with the terms and conditions of the grant or contract. (Grants from the NIH, NSF and some other Federal agencies do not require an invoice for payment.)

• Carryover of unobligated funds ® This term is most commonly applied to grants and cooperative agreements. “Unobligated” funds are funds that have not been expended and are not encumbered. If the Report of Expenditures (ROE) indicates that unobligated funds remain at the end of a budget period, refer to the award document to determine whether the funds may be carried forward to the next budget period and, if so, whether Sponsor approval for the carry-forward is required.
  • If Sponsor approval is required, the administrator should return the verified ROE to Restricted Funds. The administrator and PI must then prepare a letter to the Sponsor to request approval for carryover of the unobligated funds to the next budget period. This letter requires signature of the PI and the authorized institutional official in ORD. The letter to the Sponsor should include a brief explanation of why funds remain unexpended and a justification as to how the funds will be used in the next budget period. A budget may be required by the Sponsor. Be certain to account for facilities and administrative (F&A) costs when planning the budget for the unobligated funds.
  • If Sponsor approval is not required, the administrator should return the verified ROE to Restricted Funds along with a completed Carryover Allocation Form.

• Final Reports: Typical reporting requirements
  • Final financial reports (expenditure reports) are submitted to the Sponsor by Restricted Funds Accounting, based on the Report of Expenditures that has been approved by the PI and departmental administrator who monitors the FAS account.

  • Final Technical Progress Reports are prepared by the PI and submitted to the Sponsor according to the instructions in the award documentation. A copy of the Final Technical Progress Report and the transmittal letter to the Sponsor should be sent to ORD for University files.

  • Invention Reports are prepared and signed by the PI and then forwarded to ORD for authorized institutional signature. If the sponsor does not require PI signature, the invention information may be submitted by the PI via memo or e-mail. ORD will verify the PI's report of inventions and will sign and submit the report to the Sponsor.

  • NSF Award Reports must be submitted electronically via Fastlane. However, they are prepared as all other awards: Financial Reports are submitted by Restricted Funds Accounting and Technical Progress Reports are submitted by the PI. Please forward a paper copy of the final technical report to ORD, for University files.

  • National Research Service Award Termination Notices are signed by the fellow/trainee, by the sponsor (mentor) or training program director, and by Restricted Funds Accounting. Provide a copy of the signed Termination Notice to ORD.

  • Clinical Study Data ® When a clinical study ends, advise ORD of the location at which clinical study records and data will be stored. Refer to the award document (clinical study agreement) to determine Sponsor requirements for record retention. At minimum, FDA regulations (found at 21 CFR Section 312.62) state that an investigator shall retain clinical trial records for a period of two years following the date a marketing application is approved for the drug for the indication for which it is being investigated; or, if no application is to be filed or if the application is not approved for such indication, until two years after the investigation is discontinued and FDA is notified. In order to comply with these regulations, the study Sponsor usually notifies the Principal Investigator when such an event occurs, and requires that the Principal Investigator or the University notify the Sponsor prior to destroying any study records. Copies of any such notifications should be provided to ORD for the official agreement file.