Overview. The post-award process of federal grant management at an academic institution begins once a grant has been awarded and focuses on ensuring the project is carried out in compliance with sponsor regulations, institutional policies, and the approved budget. This phase includes financial management, reporting, subrecipient monitoring, and adherence to effort and cost-sharing requirements. Effective post-award oversight ensures accountability, supports project success, and protects the institution from audit findings or financial penalties.
Award Acceptance & Setup
Notice of Award (NOA) Review
- After final award decisions are made, the awarding agency issues a Notice of Award (NOA) to the selected entities. The NOA serves as the official and legally binding confirmation of the grant. By accepting the award—either by signing the grant agreement or drawing down funds—you and your organization agree to fully comply with all terms and conditions of the grant. As a recipient, you are also bound by applicable federal statutes, regulations, and policy requirements.
- 2 CFR Part 200 sets uniform requirements for managing federal awards, including financial management, internal controls, and audit standards. It ensures that all costs charged to awards are allowable, reasonable, allocable, and well-documented under detailed cost principles in Subpart E.
- The NSF PAPPG award conditions outline the requirements recipients must follow after receiving an NSF grant. These include compliance with 2 CFR Part 200 and NSF-specific policies on financial management, prior approvals, reporting, and allowable costs. Recipients must submit annual and final reports, ensure RCR training, manage conflicts of interest, and follow the approved data management plan. NSF support must be acknowledged in publications, and institutions must maintain proper oversight of subawards, records, and compliance with civil rights laws.
Negotiating Award Terms (if applicable)
Negotiating award terms is a critical step in the grant lifecycle, especially for complex or high-value awards. It allows recipients to ensure the terms are realistic, compliant, and aligned with institutional policies before accepting the award.
Intellectual Property (IP) clauses
Federal grant agreements define the ownership, rights, and obligations related to inventions, data, and other intellectual assets developed under the award. These clauses protect both the interests of the recipient institution and the federal government.
Publication restrictions and data rights
Federal research funding supports the dissemination of knowledge, so open publication is encouraged. 2 CFR § 200.315(b) Intangible Property “The Federal awarding agency reserves a royalty-free, nonexclusive, and irrevocable right to reproduce, publish, or otherwise use... any work developed under a Federal award.”
- Permitted Restrictions include temporary publication delays to protect IP for patent filing
- If you anticipate any possible delay as best practice you can include a statement in the proposal clarifying intent to publish, and negotiate any delays ahead of time (e.g., “Publication will be delayed no longer than 60 days for patent review”).
In accordance with 2 CFR § 200.315(d) – Data Ownership and Use; Recipients retain rights to data produced under the award, but the federal agency has the right to obtain, reproduce, publish, or use the data.
- NIH: Data sharing plans are required for most grants; large projects may need Data Management and Sharing (DMS) Plans.
- NSF: Requires a Data Management Plan (DMP) in all proposals, outlining what data will be shared and how.
Indemnification, liability, or export control terms
Sponsored project Agreements may include indemnification, liability, or export control terms that require careful review. These terms can have legal or compliance implications, so it’s important to flag them early. Indemnification clauses, which obligate one party to cover the losses or legal liabilities of another, may conflict with institutional or state policies and often require legal or administrative approval. Liability terms should be evaluated to ensure they do not expose the institution to unacceptable risk or uninsurable claims. Export control clauses must be reviewed to ensure compliance with federal regulations such as ITAR or EAR, particularly when research involves controlled technologies, foreign collaborators, or travel outside the U.S. All such terms should be flagged during contract negotiation and reviewed by legal, research compliance, or sponsored programs offices as appropriate.
Internal Account Setup
Once your grant has been awarded and all compliance checks are complete, the university will establish a unique fund number in the financial system to track your project’s expenditures. This index acts as your official grant account, allowing you to charge salaries, supplies, travel, and other approved costs to your project. It’s important to wait until the index is set up before incurring expenses, as retroactive charges may require special justification. If you have questions about your index, budget, or allowable expenses, your grants analyst or post-award contact in Sponsored Programs is your go-to resource.
When your grant is set up, the awarded budget is divided into specific categories or budget lines—such as salaries, fringe benefits, supplies, travel, and equipment—based on what was approved by the sponsor. These categories help ensure that spending aligns with the grant’s approved scope and complies with sponsor and university policies. It’s important to charge expenses to the correct budget lines to avoid overspending or the need for prior approvals to rebudget. If you're unsure where a cost should be charged, your post-award research analyst (RA) can help you navigate the budget structure and keep your project on track.
As a Principal Investigator (PI), you are responsible for overseeing how grant funds are spent and ensuring all expenses are allowable, allocable, and reasonable. Setting up internal controls—such as reviewing monthly budget reports, keeping detailed records, and approving expenses before they’re charged—helps prevent errors, overspending, or noncompliance with sponsor requirements. Delegating routine tasks to staff is fine, but it’s essential that you stay actively involved in monitoring your budget. Regular communication with your Research Analyst and maintaining clear documentation are key practices that support accountability and audit readiness.
PI Orientation
Following the receipt of an award, Principal Investigators will participate in a mandatory PI orientation with key sponsored programs personal and administrative staff. This meeting is designed to ensure a smooth start to the project by reviewing the award terms and conditions, budgetary and compliance requirements, reporting expectations, and available administrative support. It also provides an opportunity to clarify roles and responsibilities, address questions, and align on project goals and timelines. This collaborative session lays the groundwork for effective project management and compliance throughout the life of the award.
As a Principal Investigator, maintaining compliance with institutional and federal regulations is a critical responsibility. Research involving human subjects must receive approval from the Institutional Review Board (IRB) before initiation. This ensures that studies are conducted ethically, with appropriate safeguards for participant rights and well-being. Similarly, all research involving animals requires prior approval from the Institutional Animal Care and Use Committee (IACUC), which oversees the humane treatment and use of animals in research.
In addition, PIs must disclose any potential conflicts of interest (COI) that could affect the design, conduct, or reporting of their research. These disclosures help maintain transparency and public trust in the research process. Finally, Responsible Conduct of Research (RCR) training is essential for PIs and research staff to uphold the highest standards of integrity and accountability in research. Regular engagement with these compliance areas not only fulfills institutional obligations but also supports the ethical foundation of scholarly work.
As the steward of sponsored project funds, the Principal Investigator (PI) holds primary responsibility for the financial management of their award. This includes ensuring that expenditures are allowable, allocable, reasonable, and in compliance with sponsor guidelines, institutional policies, and the approved budget. PIs must review and monitor financial reports regularly, work closely with their project Research Analyst (RA) to track spending, and promptly address any discrepancies or budget modifications. Additionally, PIs are accountable for meeting all financial reporting deadlines required by the sponsor, including progress reports that may be tied to continued funding. Active engagement in financial oversight is essential to maintaining project integrity and avoiding compliance issues.
Hiring
Principal Investigators may hire individuals to work on their grant-funded projects, provided that the positions were included in the approved budget and described in the grant proposal. Hiring must follow CSUSB and UEC policies and procedures, including adherence to HR and payroll guidelines. All personnel hired must have roles that align with the scope of work and contribute directly to the objectives of the project. It is the PI’s responsibility to ensure that staffing decisions support the effective and compliant execution of the grant.
Faculty & Staff
To hire a CSUSB Faculty member or a CSUSB staff member or other staff on a grant, the PI must submit a personnel transaction report (PTR) to initiate the hiring process with UEC HR. Please note that you will need the faculty’s hourly rate to complete the PTR. For staff members, the overtime rate will be needed instead of the hourly rate. The pay rate details can be obtained from the college analyst. The grant chartfield information will also be required on the PTR and can be obtained from the Research Analyst. Once the PTR is processed, UEC HR will contact the employee to complete the onboarding process if they have not been previously hired through UEC.
- PTR - Adobe link for submission: CSUSB Faculty & State Overload PTR
- PTR example: CSUSB Faculty & Staff PTR
- Instructions: CSUS Faculty & State Overload PTR Instructions
In addition to the PTR, a UEC Faculty Additional Pay (FAP) Request will be required for Faculty every term additional payment will be issued from a grant. This will ensure faculty do not go over 1.25 FTE.
- Faculty Additional Pay Request Guide: FAP Guide
Students
To hire a CSUSB student, the PI will have to submit a different PTR form to be used for students. Hourly rate will have to be provided on the form, PIs can determine the hourly rate, it is usually the minimum rate. If PI decides to hire the student at a higher rate a justification will be required and UEC HR approval.
- Student PTR-Adobe link for submission: Employment & Employee Changes PTR
- Student PTR example: Employment & Employee Changes PTR
- Instructions: Employee & Employment Changes PTR Instructions
Independent Contractors
If an independent contractor will be rendering a service for a fee, specific documentation is required to ensure institutional compliance and timely payment. The PI must complete and submit three forms: Scope of Work; Independent/Guest Lecturer/Performer/Payment request form; Independent Contractor Determination Form; and a W-9 for the guest speaker.
The completed Independent Contractor Determination form and scope of the work must be submitted to the research analyst for approval. The RA reviews the form, checks for debarment and forwards it to Jay Wood for determination approval. Then the payment form can be submitted to the RA after services are rendered.
Paying Participants and Incentives
When research involves participant payments or incentives, Principal Investigators must ensure that all compensation methods are clearly outlined in the approved study protocol and budget, and that they comply with institutional policies, Institutional Review Board (IRB) requirements, and sponsor guidelines. Payments—whether monetary, gift cards, or other forms of incentive—must be appropriate to the level of participation. PIs should work with their research analyst and administrative staff to process payments through approved channels and maintain accurate records for auditing and reporting purposes. Proper documentation helps safeguard participant confidentiality and ensures financial compliance.
Please connect with your grant research analyst to discuss how participant incentives are processed. CSUSB student participant incentives are processed differently than non CSUSB participants, and will require to be processed through Student Financial Services.
ReceiptforIncentivePaymentstoResearchParticipants.pdf
Data Warehouse
Data Warehouse (DW) is a financial reporting system that allows Principal Investigators (PIs) to effectively monitor and manage the financial aspects of their grants and sponsored projects. It is directly connected to the CSU’s Consolidated Financial System (CFS) and is updated nightly, ensuring timely access to accurate financial data.
Reports in the DW are tailored to show the Direct Expenses, which are under the PI’s control, separately from Indirect Costs (IDC) and Revenue. PIs can run consolidated reports across all their projects, view summary totals, or drill down into specific accounts and transactions.
To receive training and account access to Data Warehouse, contact Andrea Beechko