Guidance for Managing an Award

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Allowable Cost Procedure

The TMCC Grants Office will review allowable and non-allowable costs at the beginning of every grant with the PI/PD and Grant Accountant during the Post-Award Meeting.

Grant expenses are reviewed by the Grants Accountant prior to being invoiced to the sponsor. If a cost is determined to be unallowable, the PI/PD will be required to provide a non-grant account for the expense.  

The PI/PD should be reviewing spending at least once a month and making corrections promptly when necessary for unallowable expenditures.  If you have questions, please contact the Grants Office.

Allowable costs vary with each grant and can include the following items:

• Salary and fringe benefits
• Travel
• Operating
  • Office supplies, including computers
  • Lab supplies
  • Instructional supplies
  • Tuition
  • Student support costs, e.g., books, bus passes
  • Host
• Equipment
• Construction
• Scholarships
• Participant Support
• Subcontractors

Disallowed Cost

When an awarding agency or auditor determines that an expense that the sponsor reimbursed is unallowable, the auditor will refer to it as a disallowed cost. The College must repay the disallowed costs to the Sponsor.

Unallowable Costs

Unallowable costs are those costs that the federal regulations, sponsor limits, or institutional policy prohibit the College from charging to a grant account. For example, if a sponsor limits the award to salary costs only, travel expenses would be unallowable. Unallowable costs also include items expressly forbidden by regulations, such as purchasing alcohol and lobbying with federal funds.

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Cost Principles and Federal Policy

Principal Investigators (PIs) and Project Directors (PDs) are expected to have a basic understanding of the cost principles and federal regulations to ensure that only allowable costs are charged to the project account.

Costs on grants are allowable if they meet the following criteria:

Reasonable

Federal regulations consider that a cost is reasonable if the item purchased and the cost of the item reflects the action that a prudent person would take under similar circumstances at the time the individual makes the purchase. The cost must be necessary to the College’s operations and/or the sponsored project’s performance. The purchase must comply with established college, state and federal regulations and the purchaser must be acting with due prudence in carrying out their responsibilities to the College.

Allocable

A cost is allocable to a specific sponsored account if the goods or services involved are assignable to that account in accordance with the relative benefits received or other reasonable allocation. A cost is allocable to a sponsored account if it is incurred solely in order to advance the work on the project.

Conformance with Policy and Regulations

Purchases must be made in conformance with federal and sponsor regulations and institutional policies and procedures. The federal regulations that apply to grant costs incurred by TMCC are located in the Code of Federal Regulations at 2 CFR 200. Most of TMCC’s sponsored awards are subject to these regulations.

The regulations are in six subparts:

1. Subpart A: Acronyms and Definitions
2. Subpart B: General Provisions – key item in this part is regulation concerning conflict of interest
3. Subpart C: Pre-Federal Award Requirements and Contents of Federal Awards
   • Use of agreements
   • Federal agency review of merit
   • Federal awarding agency review of applicant risk
   • Application requirements
4. Subpart D: Post Federal Award Requirements
   • Standards for Financial and Program Management
   • Property Standards
   • Procurement Standards
   • Performance and Financial Monitoring and Reporting
   • Subrecipient Monitoring and Management
   • Record Retention and Access
   • Remedies for Noncompliance
   • Closeout
   • Post-Closeout Adjustments and Continuing Responsibilities
   • Collection of Amounts Due
5. Subpart E: Cost Principles
   • General Provisions
   • Basic Considerations
   • Direct and Indirect (F&A Costs)
   • Special Considerations for Institutions of Higher Education
   • General Provisions for Selected Items of Costs
6. Subpart F: Audit Requirements
   • Audits
   • Auditees
   • Federal Agencies
   • Auditors
   • Management Decisions

Consistency

The College must be consistent in assigning costs to cost objectives. Salary, operating and tuition are examples of cost objectives. The College may charge costs as either direct costs or F&A costs, depending on their identifiable benefit to a particular project. When costs are for a similar circumstance, the federal government expects the College to treat the costs consistently regardless of the source of funding. 

The last principle is that purchases are not included as a cost in any other federally supported award (unless specifically authorized by statute).

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Tips for Managing Types of Costs in the Award

Payroll Charges and Effort Reporting

Federal regulations require that the College complete effort reporting for all salary charged to sponsored accounts. Effort reporting is the process of confirming that the payroll distribution was reasonable for the employee’s activity in an effort reporting term. 

Effort reporting is the process of confirming that the payroll distribution was reasonable for the employee’s activity in an effort reporting term. In order for effort reporting to work correctly, the employee’s payroll allocation must be correct on the Payroll Action Form or PAF. PI/PDs will know the PAF is set-up correctly when the account’s monthly balance and activity report shows the correct payroll charge.

Key items in effort reporting:

• Effort is not certifying payroll. Effort reporting is the process of confirming that the payroll distribution was appropriate in relation to the employees work activities in a specific reporting term.
• Effort is a percentage of the employee’s total institutional activities.
• It confirms to the sponsor that you have met your commitment to work on the project based on the proposal.
• Effort reporting is not required for employees paid based on hours recorded on timesheets.

Certifiers must verify that the effort is correct prior to certification. Recertifying effort is not possible except in very rare circumstances. If you are not sure the effort is correct, do not certify the form. Resolve your concerns before completing the report.

Employees may face financial and criminal consequences for falsifying effort.

Operating

Sponsoring agencies reimburse the College for office supplies through the Facilities and Administrative (F&A) rate. Therefore, the purchase of office supplies are restricted, however there are exceptions. For example, if the project requires a mail survey, the purchase of envelopes would be allowable because the quantity of envelopes needed exceeds normal business activities.

Travel

Travel can be charged to grant accounts if the personnel are working on the project. There should be an effort report or other payroll documentation that matches the travel expense. In some cases, the sponsor must pre-approve the travel. The PI should work with the Grants Office to obtain the prior approval if required.

Equipment

Federal regulations require that the sponsor approve equipment purchases, either in the proposal or in a special request during the award phase. TMCC equipment purchases are made in compliance with the policies set forth by the Nevada System of Higher Education/Business Center North (NSHE-BCN).

In late Spring 2017, Business Center North began implementing the procurement section of new federal regulations, known as Uniform Guidance (2 CFR Part 200).

Consultant or Vendor Agreement

Consultant or Vendor Agreements must comply with State of Nevada purchasing regulations. It is not allowable to enter into a verbal agreement with a consultant or vendor prior to the fair and open competition process.

After the College issues a contract to the consultant or vendor, the PI is responsible to notify the TMCC Grants Office if there is an issue with the performance of the consultant or vendor. If the College uses a sponsored account to pay for a consultant or vendor and the work is not satisfactory, the PI/PD should submit a JV to move the expense to a non-sponsored account while the performance issue is resolved.

Sub-Recipient Awards and Monitoring

When TMCC issues a subaward to another institution, the College has a number of obligations and must refer to policies in the Uniform Guidance for “Subrecipient Monitoring and Management” found in the Code of Federal Regulations at 2 CFR 200. The College is responsible to ensure the entity is eligible to receive a sub-award and has the required mechanisms to ensure compliance with the regulations for allowable costs, personnel, project reporting, and any special terms and conditions of the award.

The PI is responsible for the following:

• Support the administrative process and facilitate professional relationships between the subrecipient and the College.
• Review and sign all invoices.
• Ensure that the technical reports from the subrecipient are submitted on time.
• Review technical reports for appropriateness.
• Request amendments to the subaward through the Grants Office.
• Confirm that the subrecipient ensures that all compliance is in place and up to date.
• Bring concerns about project performance, invoicing or use of funds to the immediate attention of the Grants Office. Do not approve invoices for payment if there are concerns.

Program Income

Federal regulations define program income as income earned by the College generated by a grant. For example, if the project is to put on a conference, the registration fees paid by the conference attendees are program income.

All principal investigators should plan the use of program income due to a possible impact the program income will have on the scope of work of the award. Federal regulations dictate that the College must manage income revenue in one of three ways, depending on the sponsor’s policies:

• Matching Method: The College can use the program income as cost share.
• Additive Method: The College can add the program income to the amount of total project costs.
• Deductive Method: The College must deduct the program income to the amount of project costs paid by the sponsor.

Example: A sponsor awards $100,000 for a project. The project generates an income of $30,000.

• Matching Method: If the College were required to supply matching funds, e.g., $50,000, the College would now have to provide $20,000.
• Additive Method: The total project cost will be $130,000.
• Deductive Method: The sponsor will now only fund $70,000 of the project's costs.

The College must use the same cost principles in the management of the program income costs. Expenses that are unallowable on the main project account are also unallowable on the program income account.

Timing of Purchases

Purchases should not occur during the last month of the project unless the PI/PD needs the item to complete the project. Unspent funds belong to the sponsor. Auditors often disallow purchases made during the final weeks, based on the assumption that the PI is simply using up the money. PIs/PDs are encouraged to plan ahead and purchase in a timely manner, and be certain that the purchase is in accordance with the budget as well as being allocable to the project.

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Reporting Requirements

Financial, administrative, and progress reporting are consistent requirements that sponsors place on the College for sponsored projects. This reporting obligation requires that the Principal Investigators (PIs), Project Directors (PDs) and the TMCC Grants Office work together to complete the reports on time, with the correct information and in the correct format. At the beginning of each award, the TMCC Grants Office ensures that PI/PD’s and the Grant Accountant understand all reporting requirements and deadlines during the Post-Award Meeting. If a PI/PD has any questions, concerns, or delays with any required reporting he/she should contact the TMCC Grants Office to resolve issues.

Financial Reports

Financial reports usually involve three types of information:

• Expenditures that have been incurred.
• Amount of money paid by the sponsor.
• Amount of money left to spend on the award.

TMCC’s Controllers maintains the official records of all project expenditures. This includes purchasing card receipts, travel claims, effort reports, timesheets, and/or purchase orders. The College uses the documents that have an authorized signature that directed the charge to the sponsored account as supporting documentation. The Grant Accountant will use these documents when a sponsor or auditor requests such documentation. The Grant Accountant will work with the PI/PD to ensure all Financial Reports are submitted correctly and timely.

Administrative Reports

Administrative reports can include inventory, title to property, and patent and invention reporting. The Grants Office will work with the PI/PD to complete these documents at the project closeout.

Project Reporting

PIs/PDs communicate the projects progress to the sponsor by completing project reporting. PIs are responsible for completing:

• Progress reports
• Technical reports
• Other reports as required by the sponsor (e.g., NSF Project Outcomes)

PI/PD’s need to follow all sponsor guidelines for the submission format and frequency. The PI is also responsible for submission of all technical reports required under the terms of the award, as well as other agreed upon deliverables such as data, graphs or software.

Late Reports

If reports are late, incomplete, or missing, the sponsor may refuse to:

• Pay invoices
• Process new proposals
• Process new awards
• Process award extensions
• Approve budget modifications

Dissemination of Project Results

Dissemination of project results and products is an extremely important part of sponsored funding. The federal government is finalizing data standards in order to facilitate the dissemination of project results.

Projects disseminate information such as evaluation results, handbooks and manuals, curriculum and materials developed, project design or model, surveys and instruments developed, and best practices and lessons learned.

PI/PD’s should also look for opportunities to disseminate results through conference presentations, websites, articles in professional journals, professional organizations, associations and community college organizations.

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Managing Changes to the Award or Budget

Award Modification/Amendment

A modification or amendment is an award document issued by the sponsor that changes an existing award. The College may initiate a request for a change in the award or the sponsor may initiate the action.

Examples of a modification or amendment include:

• Change in scope of work and/or PI
• Incremental/continuation funding
• Carryover approvals
• Adding or deleting special terms and conditions
• Changes in funding levels
• Administrative changes initiated by the sponsor
• No-cost time extensions

Depending upon the nature of the modification/amendment, the TMCC Grants Office will work with the appropriate personnel to make the necessary changes to TMCC’s financial and administrative records.

Internal Budget Revision

During the conduct of the project, the PI may determine that an internal budget revision is necessary to cover all of the project costs. Some sponsors allow the PI/PD the flexibility to determine how to use project funds to achieve the goals of the project. Sponsors generally permit budget changes needed to meet project requirements; however, PIs need to be aware of the circumstances that require prior approval of budget revisions by the sponsor.

The Grant Accountant or the Grants Office will review the sponsor’s restrictions prior to processing an internal budget revision request.

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Fiscal Controls and Location of Grant Documentation

Strict controls on expenditures and record-keeping are required to ensure that TMCC complies with federal and state law and with the regulations and guidelines of the funding or contracting agency.

Account Setup

The Grant Accountant is responsible for setting up grant accounts in Workday based on the award information provided by the Grants Office and the PI/PD during the Post-Award Meeting. Workday generates a unique account code for each grant in order to separately track income and expenses. The Grant Accountant will verify that the correct fund type is assigned to the grant during the account setup.

Billing

The Grant Accountant is responsible for the submission of all invoices for reimbursement of expenditures. Invoices are prepared as directed by the sponsor’s award document.

A TMCC-generated invoice or other specific agency form(s) are used to collect reimbursement funds. Certain awards use electronic drawdowns and funds are not drawn in advance of actual expenditures (unless directed by the sponsoring agency).

Once approved, the invoice is entered into Workday and an invoice number is generated. 

Drawdown of Federal Funds and Federal Funds Reporting

Unless the grant provides otherwise, a drawdown of Federal Funds for expense reimbursement may only be requested after the expense has been incurred. As each drawdown request is processed, the Controller or designee will review the drawdown request prior to submission. The review will compare the drawdown request to the applicable reports to ensure that the amounts on the drawdown are accurate. The Grant Accountant is responsible for ensuring these procedures are followed.

Personnel Activity Monitoring

Effort Reporting will be completed for all TMCC grants requiring time & effort reporting.  Effort certification will be quarterly unless stipulated otherwise in the grant.

The Grants Accountant will send effort certification requests to PIs through Workday. The PIs will verify the effort and account numbers reflected on the report. Once the effort and account numbers have been verified, the effort report will be sent to the employee and supervisor for approval.

Record Documentation and Retention

Documents that are maintained in the Grants Office:

• Proposal files
• Notice of Award or fully-executed copy of award agreement
• Award Budget
• Post-Award Meeting Form
• Award modifications
• Progress and final reports

Documents that are maintained in the Controller’s Office:

• Award agreement with budget
• Budget revisions
• Invoices
• Effort Reports
• Financial Reports

Documents that are maintained in the Auxiliary Services Office:

• Purchase Requisitions
• Purchase Orders
• Travel requests and claims
• Departmental Purchase Orders

Documents that are maintained in the Human Resources Office:

• Personnel contracts

Documents that are maintained in the employee’s department:

• Original timesheets

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General Provisions and Definitions

In this section we have pulled together definitions of many terms commonly used in sponsored project administration. Use this list to become better acquainted with our terminology and general policies. For example, search for "award", then try, "costs."

Administrative Acceptance

The administrative process to accept grant awards includes the review of the award, signature of Authorized Organizational Representative (AOR), Post-Award Meeting and account setup. The Nevada System of Higher Education (NSHE) Chancellor’s Office has issued guidance on who has signature authority to commit the College in a legal agreement. In most cases, the President is the AOR, but in some cases, the Chancellor’s Office must approve the award.

Allowable Cost

Costs on grants are allowable if they meet the following criteria:

• Reasonable
• Allocable
• In conformance with Federal and sponsor regulations and institutional policies and procedures
• Treated consistently regardless of the source of funds
• Not included as a cost in any other federally supported award (unless specifically authorized by statute)

Allocable Cost

A cost is allocable to a specific sponsored account if the goods or services involved are assignable to that account in accordance with the relative benefits received or other reasonable allocation. The PI can make the purchase if the cost is necessary to advance the work on the project.

Audit

An audit is a review of financial transactions, documentation, accounting procedures and systems by external or internal auditors. Various entities perform audits, examples include:

• Nevada System of Higher Education (NSHE) Internal Audit Division
• Private audit firm hired by NSHE to complete the annual A-133 audit
• Federal agency on agency’s awards (can be agency staff or private firm they hire)
• Federal agency’s Office of Inspector General (OIG) (can be OIG staff or private firm they hire)
• State agency (performed by agency’s employees)

Award

An award is a grant, contract, or agreement issued by federal, state, or private entity that provides funds for a specific project to TMCC.

Award Acceptance and Post Award Meeting

After the TMCC Grants Office reviews the fully executed award, the award agreement is accepted and the Post-Award Meeting is scheduled. During the Post-Award Meeting, the PI/PD, Grants Office and Grant Accountant will discuss the key aspects of the award and take responsibility for various start-up tasks. This will also include a discussion about the budget, allowable costs, reporting requirements, and the account setup.

Award Amendment

An amendment changes the terms of the award, e.g., the end date or total funding amount.

Award Letter

An award letter notifies the College that the funding agency has funded a project. The award letter includes information such as the start and end dates of the award, the amount funded and applicable regulations for the management of the project.

Budget

The budget is the spending plan for a proposed project. At the time of the award, the approved budget becomes a spending guide for the project. In some cases, the sponsor places restrictions on the College’s authority to modify the budget and/or to spend from certain categories.

Budget Category

A portion of the budget designated for certain types of expenditures such as salaries, fringe benefits, travel, operating, equipment, participant support, sub-awards or sub-contracts, indirect (F&A) costs, etc. TMCC refers to these categories as spend categories.

Carry Forward or Carryover

Carry forward is unspent funds from the prior year that the sponsor allows the College to carry into the next funding year. Sponsors do not like under-spending and carryover of large amounts from year to year. The goal is to expend all of the funds per the proposed budget. The PI should anticipate that the sponsor will not approve the carryover requests.

Closing a Project

Federal regulations require that the College complete the close out of a sponsored account within 90 days after the end date of the project. After the end date of the award, the PI should make one last review of the expenses posted to the account for any unallowable costs. If the account is over-spent, the PI must move the charges to other College funds to bring the award account to zero. If the PI spent less than the award amount, the final financial report will reflect this information. If the sponsor has already paid the College for the full amount of the award, the College will return the underspent amount to the sponsor.

Cohort

A cohort is a student group such as nursing students who participate together in a program. Usually programs with cohorts involve tracking and reporting of individual member and cohort progress.

Collaboration

Collaboration is a partnership in which key personnel from different institutions have substantial involvement in the development and performance of the project and the funding source makes only one award. The lead institution issues subcontracts or subawards to the other collaborating institutions.

Committed Effort

Committed effort is the amount of effort proposed in a sponsored project proposal or other project application that the sponsor accepts. Committed effort should be directly charged to the sponsor. Federal regulations require that the sponsor must give prior approval on a reduction of more than 25% in PI effort on a grant.

Conformance

Conformance is one of the cost principles. The College is required to make purchases or pay for salary that is in conformance with limitations and exclusions as contained in the terms and conditions of award, federal regulations, and institutional policy.

Consistency

Consistency is one of the cost principles. The College must be consistent in assigning costs to cost objectives. Salary, operating and tuition are examples of cost objectives.

Consortium

A group of organizations sharing in the project aims, deliverables, finances and/or administration of a single grant. The lead institution submits the proposal on behalf of the consortium.

Continuation/Renewal Proposal

A type of proposal for additional funding that requests additional funds and time to complete a project beyond the original grant period.

Contract

A contract is an agreement to acquire services that benefit the project.

Cooperative Agreement

A financial assistance mechanism (grant) used when substantial Federal programmatic involvement with the recipient is anticipated by the funding agency during performance of the project. The Federal sponsor will specify the nature of the involvement in the offering or application guidance materials.

Cost Allocation

The method of determining the assignable cost of a particular item to one or more sponsored project accounts.

Cost Principles

The principles that determine if a cost is allowable. See also: "Allowable Costs".

Cost Reimbursement

A type of agreement in which the sponsor reimburses the College for actual allowable costs incurred in performance of the work.

Cost Share

Cost share or match is the portion of total project or program costs paid by the College or a third-party partner.

Cost Transfers

A cost transfer is an accounting entry that credits the account and moves the expenditure to a new account. Cost transfers are appropriate to correct technical errors, move charges on a memo account, ensure proper allocation of costs among accounts, and remove unallowable costs. Cost transfers are not appropriate to spend down an account. The College uses the term journal vouchers for cost transfers.

Direct Cost

Direct costs are, "those costs that can be identified specifically with a particular sponsored project, an instructional activity or any other institutional activity, or that can be directly assigned to activities relatively easily with a high degree of accuracy." (2 CFR 200.413)

Disallowed Cost

When an awarding agency or auditor determines that an expense that the sponsor reimbursed is unallowable, the auditor will refer to it as a disallowed cost. The College must repay disallowed costs to the sponsor.

Dissemination of Project Results

Strategies to let colleagues or organizations know about the results of a grant project. Examples include websites, publications, published articles, conference presentations, workshops etc.

Effort

Effort is the proportion of time spent on any activity. TMCC employees report effort as a percentage of their institutional activities.

Effort Certification

Certifiers must verify that the effort is correct prior to certification. Recertifying effort is not possible except in very rare circumstances. Concerns about the effort distribution shown on the page must be resolved before completing the report. Employees may face financial and criminal consequences for falsifying effort.

Equipment

Permanent equipment is an item of tangible property with a minimum cost of $5,000 and that has a useful life greater than one year.

External Evaluator

A subject matter expert external to the project with the background and qualifications to conduct a high-quality evaluation based on the project requirements. The College must hire evaluators in compliance with appropriate contracting rules.

Facilities and Administrative (F&A) Costs

Facilities & Administrative Costs or indirect costs are those expenses not easily identified as a cost that solely benefited one project. The sponsor reimburses the College for such costs via the Facilities and Administrative Rate (F&A). F&A costs fall into one of two categories:

• Facilities
  • Labs and classrooms
  • Library and office space
  • Electricity and internet
• Administrative
  • Deans and department administration (including administrative assistants)
  • Grants administration
  • Office supplies

The F&A rate-setting process begins with the classification of costs for the prior fiscal year. The College assigns the costs to a prescribed set of cost pools determined by federal regulation. The College uses the cost pools in the calculation of the rate. The College submits the proposed rate to the Department of Health and Human Services, Division of Cost Allocation (DCA) in San Francisco. DCA assigns a reviewer who goes through the proposal and supporting accounting schedules. Based on the review, DCA may accept the proposed rate or set a lower rate. Typically, the rate is set for four years.

Facilities & Administrative Cost Recovery and Distribution

The College recovers the allocable F&A during the invoicing process. The College uses the rate agreed to by the sponsor and charges the sponsor based on the method determined during the proposal phase, e.g., MTDC or TDC. If the award is eligible for the Grant Indirect Cost Sharing program, the financial system will automatically distribute the recovered F&A.

Federal Register

Contains proposed and final guidelines, and other administrative regulations of programs as announced by Federal agencies in precise wording of the law.

Fiscal Year

The twelve-month period that determines an entity’s financial year, often stated as FY. TMCC’s fiscal year is July 1 through June 30. (For example, FY16 is the fiscal year for the period July 1, 2015 to June 30, 2016.) The Federal Fiscal Year (FFY) is October 1 through September 30.

Formula Grants

Funds distributed by the federal government (usually to state agencies) for use in specified projects. For example, the State of Nevada awards the Perkins Act funding based on a formula that includes the number of TMCC Pell Grant recipients.

Fringe Benefits

The College pays employee benefits such as life and health insurance, retirement, unemployment compensation and workers compensation in addition to salary. Benefit packages change yearly and vary by employee depending upon his/her benefit selections. Fringe benefit costs are generally allowable on the sponsored account provided that the proportion of costs is consistent with the employee’s level of effort on the project.

Full Time Equivalent

A full-time equivalent measure is a way of equating the work of full- and part-time personnel. A full-time employee counts as one FTE. The FTE for a part-time employee is based on the percentage of a full time position that the College hires the employee to fill. For example, four employees who each work one-quarter of a full-time position are equal to one FTE employee.

Gift

A gift or donation is a voluntary transfer of money, services, or property (e.g., equipment, property, personnel time, etc.) from a donor without any expectation of or receipt of direct economic benefit or provision of goods or services. Donors make gifts to TMCC through the TMCC Foundation. The Foundation provides the donor with appropriate donor recognition and IRS tax documentation.

Grantee

A grantee is a recipient of a grant.

Institutional Activities

Institutional activities include all job duties or assignments that benefit the College. These activities generally include:

• Working on a grant or other sponsored project
• Instruction
• Maintaining office hours
• Advising students
• Supervising employees
• Serving on College committees
• Institutional/unit governance
• Other scholarly activities that directly benefit the institution

Key Personnel

Key personnel assume the primary leadership for grant projects such as Principal and Co-Investigators, Project Directors, etc. It is best to name as few people as possible under the key personnel heading.

No Cost Extension (NCE)

The College submits a no-cost extension to request a new end date of the grant from the sponsor. The TMCC Grants Office will work with the PI to determine the date to request from the sponsor. As the name implies, the College does not ask for additional funds. The College must request an NCE prior to the award end date. The level of key personnel effort commitments remain the same during the no-cost extension.

Pass-Through Entity

The pass-through entity provides an award to a sub recipient to carry out a portion of approved Statement of Work on a sponsored project. The pass-through entity assumes responsibility for oversight and management of a sub award. TMCC serves as the pass-through entity for sub-awards issued under its sponsored projects.

Program Officer

The sponsor’s employee or contractor who has the task of monitoring the project, providing technical assistance to the project, approving major changes, and insuring that the objectives are carried out within the framework of regulations.

Proposal

An application submitted to an external funding source that may lead directly to a funded award. All proposals require institutional approval by the TMCC President.

Reasonable Cost

Federal regulations consider that a cost is reasonable if the item purchased and the cost of the item reflects the action that a prudent person would take under similar circumstances at the time the individual makes the purchase. The cost must be necessary to the College’s operations and/or the sponsored project’s performance. The purchase must comply with established College policies and the purchaser must be acting with due prudence in carrying out their responsibilities to the College.

Record Retention

Nevada System of Higher Education requires that the College retain all project-related documentation for seven years after the submission of the final expenditure report unless the terms of the grant dictate a longer retention period. However, some sponsors may specify a longer timeframe in the award document. Applicable records can be, but are not limited to, financial, personnel, lab notes, and computer files.

Reporting Requirements

Performance and fiscal requirements set by the funding source. The Principal Investigator/Project Director is responsible for the performance report and the Grant Accountant is responsible for producing and submitting financial reports.

Requests for Proposals (RFP)/Solicitation

The request for proposal or solicitation is an announcement by an agency that it is accepting proposals to accomplish a specific objective. The solicitation typically contains detailed instructions related to the written proposal.

Sponsored Accounts

TMCC sets up sponsored accounts to provide for the separate management and reporting of funds granted by sponsoring agencies. The College manages the budget and project expenses in the account.

Sponsored Project

Granting agencies award sponsored projects to the College in support of research, instruction, training, testing, service, or other scholarly activities under an agreement where the following conditions apply:

• The sponsor requires that the Institution signs the proposal and award.
• The project has a budget that identifies expenses by activity, function, or project period.
• The project requires fiscal accountability including financial reports to the sponsor, an audit provision, or the return of unexpended funds at the conclusion of the project.
• The agreement obligates the PI to report project results or convey rights to tangible (i.e., equipment, reports, etc.) or intangible properties (i.e., data, copyright or inventions) resulting from the project.
• The agreement requires considerations such as indemnification or imposes other terms of legal accountability.

Stewardship

The obligation to be the responsible caretaker of public and private funding resources awarded to the College.

Submission Deadlines

The sponsoring agency provides the date and time by which the College must submit applications for grants or contracts. Pay close attention to whether the deadline is "to be received at the agency", "by the deadline", or "postmarked" by the deadline and whether the deadline is local time or time at the funding source’s location.

Supplant

Supplanting funds is an improper use of sponsored funds to pay for ongoing activities that are budgeted for State accounts.

Total Institutional Salary (TIS)

Total Institutional Salary is the compensation paid to an employee for all institutional activities. Total institutional salary does not include any income that an individual earns for external work that does not use significant TMCC resources such as individual consulting or community service efforts.

TIS includes compensation from these sources:

• State of Nevada
• Grants and other Sponsored Projects
• Gifts and Endowments
• Other College Funds

Unallowable Costs

Unallowable costs are those costs that the sponsor does not allow to be charged to a sponsored project account. For example, if a sponsor limits the award to salary costs only, travel expenses would be unallowable. Unallowable costs also include items expressly forbidden by regulations, such as purchasing alcohol and lobbying with federal funds.