GAP 200.190, Parent/Child Sponsored Project Management

I.    General

II.   Roles and Responsibilities

III.  Specific Parent/Child Management Processes

IV.  Escalation Procedures

V.   Exceptions

 

 

I. General

Duke University establishes a specific WBSE for each externally sponsored project. This is done to create a financial oversight process for internal control and compliant project management. Responsibility and accountability for compliant programmatic and financial management of the funded project rests with the Principal Investigator and “owning” department of the WBSE. Under certain circumstances (detailed below), Duke may allow the establishment of a separate internal WBSE directly related to an externally funded sponsored project. The relationship between these two separate WBSEs is generally defined as a “parent/child” relationship. A separate WBSE allows for localized management of certain aspects of the funded project. The parent is ultimately responsible to the sponsor for all activities of the project, but the child is responsible for managing the subcode(s) in its BFR.

Duke University defines a “parent/child” relationship as a mechanism established in University systems to provide for segregated management of funds for sponsored projects performed at Duke and funded under a single prime award to the University. 

The University allows the establishment of internal child WBSEs in SAP to facilitate financial and project management.

These WBSEs may be established for:

• Identification of clearly defined scopes of work and/or multiple-PI project leadership, as specified in the original proposal submitted to the sponsor (e.g. PPGs)
• Convenience in project management when multiple faculty are collaborating within or between BFRs even when not clearly separated and budgeted in the original proposal
• Identification of pre-arranged Facilities & Administrative Costs (F&A) distribution or other financial management reasons

This General Accounting Procedures (GAP) applies to all parent/child relationships. Subcodes may also be established for internal awards, where the parent PI allocates funds for separate subprojects, generally referred to as mini-grants or pilot projects. These subcodes are often governed by clearly established rules of performance and outcome expectations, in accordance with sponsor directives. The parameters for managing these subcodes are typically more stringent than and take precedence over what is communicated in this GAP.

Parent/child relationships are subject to the following:

• Clearly defined roles and responsibilities on the part of the parent’s and the child’s research administration structure
• Clearly defined processes
• Management tools to ensure appropriate compliance
• The parent and the child each retain responsibility for the allowability, allocability and reasonableness of charges to their own code, including responsibility for any disallowed charges or overdrafts on their code

 

II. Roles and Responsibilities

Duke University standard compliance responsibilities apply to all funded projects. Departments should manage independently to these general expectations, regardless of the designation as a parent or a child. These roles and responsibilities are defined on the Research Compliance & Reporting webpage and include the requirement to adhere to sponsor and Duke rules, regulations and policies at all times. The PI of the parent project retains responsibility for oversight of all aspects of the sponsored project, which includes the parent and all children. For the purposes of this GAP, the following additional responsibilities apply to all parent/child relationships.

Parent:

• Requests creation of the subcode for the child org unit
• Establishes award management parameters that may include additional guidance to child regarding expectations, responsibilities, deadlines, and reporting requirements
• Monitors burn rate of parent and child codes to ensure appropriate expenditure pattern and project management (including effort/salary allocation)
• Ensures programmatic and financial reports submitted to the sponsor are accurate and timely (including financial closeout documentation)
• Manages the No Cost Extension (NCE) decision/process, including communicating with child regarding NCE status as applicable

Child:

• Advises the parent in a timely manner if underspending or overspending is anticipated
• Provides accurate and timely financial and programmatic information and/or reporting to parent
• Coordinates with parent as required under any special terms and conditions communicated by the parent to the child (if applicable)
• The child must seek parent approval before requesting a change to personnel effort that requires sponsor or institutional approval.

 

III. Specific Parent/Child Management Process

A.  Award Setup

1. Upon award, the parent org unit maintains ownership in SAP of the parent code, while the child org unit owns the child code. Exceptions to this require approval from the Dean’s office(s) of the relevant School(s).
2. Unusual situations may require additional guidance to clarify the operational relationship between the parent and child. A Memorandum Of Understanding (MOU) [see template] may be executed between the parent and the child org units regarding expectations of roles, responsibilities, and additional requirements (such as early close-out dates, prior approval expectations, and joint faculty appointments). If applicable, the executed MOU should be maintained on file by the parent and child org unit.

B.  Project Management

1. Project expenses may be incurred or transferred only on an org unit’s own codes; prior approval should be obtained before obligating another org unit’s code, whether it is the parent or child.
2. Only the parent can rebudget between the parent and child codes; advance notification should be provided to the child.
3. Subject to sponsor’s terms & conditions, the child may rebudget within the child code. Note that the parent is advised of this action through the eRA@Duke Rebudget/CAS tool and reserves the right to require additional information or retraction of the rebudget if necessary.
4. Balances will be netted across all project codes (parent and children) at time of Closeout per the process described in the Balance Netting Quick Reference Guide. Any requested exceptions to the standard balance netting process should be communicated between parent and child prior to submitting Closeout documents.
5. The parent manages the NCE option, and coordinates with the child regarding NCE status. The child and parent both assume individual risk in spending past the end date of the project in anticipation of an NCE. The child is always responsible for cost overruns and/or disallowed charges to the child code. Any exceptions to this responsibility should be clearly documented and communicated.

 

IV. Escalation Procedures

A.  Throughout the life of the Project:

If the child does not comply with the requirements for compliant project management at Duke, the parent may escalate resolution of the issue. Examples may include low burn rate in the child code, slow technical performance, or other issues related to the progress of the research. As a best practice, the parent Grant Manager should review with the parent PI and/or business manager, who should contact the child PI and/or business manager for resolution. Possible resolutions include but are not limited to rebudgeting funds from the child to the parent and closing the child code.

B.  At closeout:

As timely closeout action is essential to Duke’s business practices, additional escalation actions related to closeout are appropriate. The starting point for escalation of issues as the closeout deadlines approach remain those specified in the paragraph above. If these attempts do not succeed and the child has not provided the closeout documents by the established institutional deadline, the parent should escalate appropriately.

 

V. Exceptions

Exception to the processes described above is only allowed by petition to the Management Center.

Note: This guidance is administrative in nature and is not a cost reimbursement policy. Failure to comply may or may not result in adjustments of charges to the award. Noncompliance with this policy does not mean this cost is unallowable from an external perspective. Any adjustments of charges will be as required under applicable federal cost reimbursement principles. If a cost is removed from an award for any reason, whether or not related to this guidance, the cost will generally be charged to departmental funds.