Submitting Project Reports in a Timely Manner
The University of Montana’s most recent audit by the Legislative Audit Division included an audit finding concerning Principal Investigators (PIs) submitting late technical reports. As you know, the PI is responsible for preparing and submitting all sponsor-required technical reports, including progress / project reports and the final report, according to the schedule outlined in the award. Sponsoring agencies receive and review our audit reports and can question our ability to complete projects based on the failure of some individuals to complete their reports on time.
Among the actions sponsors can take when annual and/or final reports are not received by the deadline are the following:
1. The loss of expanded authorities on current and future awards.
Expanded authorities allow ORSP staff to approve some changes such as budget revisions and no-cost time extensions. Without expanded authorities, all such requests would require sponsor prior approval in writing, which could significantly delay work on the project.
2. Delays in the University receiving payments or sponsor refusal to pay outstanding invoices.
Most awards are paid on a cost-reimbursement basis. This means the University advances money to the project and then invoices the sponsor for payment. Until payment is received, the University carries the debt for costs already incurred. Failure to receive required technical reports is frequently the reason given by sponsors for not paying invoices in a timely fashion. Any costs disallowed by the sponsor due to the PI’s failure to submit required reports according to the sponsor’s schedule will be the responsibility of the PI’s unit head (dean or center director).
3. Sponsor designation of the University as a high-risk awardee.
When a project is declared high risk by the sponsor, the PI is not allowed to spend any grant funds without specific approval from the sponsor. This usually involves submitting requests to the sponsor on a periodic basis, outlining the proposed activities for the period and including a budget and budget justification that explains how the proposed expenditures relate specifically to the project’s goals and objectives. Work cannot proceed and costs cannot be incurred until the sponsor has approved in writing the specific activities and budget outlined in the request, even though the expenses were spelled out in the originally approved budget. The PI of a high-risk project also must submit detailed programmatic and financial reports for sponsor approval in order for the University to receive payment of invoices. The high-risk designation indicates that the sponsor has serious concerns about the PI’s and University’s ability to manage projects, and therefore endangers the receipt of future awards from that sponsor as well as from other federal sponsors.
4. The loss of external funding from that sponsor, not only to the individuals involved but to other University investigators as well.
In some cases, sponsors will discontinue funding and terminate the project due to delinquent reporting. Some sponsors will refuse to make new awards to anyone at the University as long as there are any delinquent reports on currently funded projects.
Failure to submit your final technical report on time also has consequences for your unit. If the final technical report for an externally funded project is not submitted on time, distribution of SPABA from the last year of the award will be delayed until the delinquent report has been submitted and accepted by the sponsor.
Because of these serious repercussions, it is incumbent upon the PI to make sure all reports are completed and submitted to the sponsor on time. Generally, final reports are due to the sponsor within 90 days of the project end date, although some awards allow less time. If additional time is needed to complete the final technical report, the PI should contact ORSP staff at least 60 days before the project end date to discuss requesting an extension of the project (note that NSF no longer allows time extensions if all the grant funds have been spent). The PI should check with ORSP staff (see list below) if there is any question concerning what reports must be filed, where they should be filed, and the due dates to the sponsor. When submitting your reports, send ORSP a copy of the transmittal letter so we know where and when it was sent. With the advent of Fastlane, grants.gov, and other electronic research administration tools, a number of agencies now use on-line reporting systems. Check with ORSP staff if you need assistance when using these to submit your reports.
Some sponsors (for example, NASA) delegate administration of reporting requirements to the Office of Naval Research (ONR). In these cases, the PI needs to submit technical reports to ONR as well as to the sponsor. When we receive notice that authority has been delegated to ONR, we send a copy of the notice to the PI so you are aware of the requirement. If you fail to submit your report to ONR when it is required, you are considered delinquent in your reporting even if you have sent the report to the sponsor.
We need to work together to make sure the University complies with the reporting requirements for externally funded projects. If you have any questions or need additional information about these requirements and procedures, please contact an ORSP staff member.