Technical/Programmatic Reporting Guidance for PIs
Technical/Programmatic Reporting Guidance
General
In accordance with Penn State Policy RA02, Principal Investigators (“PIs”) on sponsored projects are responsible for the management and conduct of sponsored activities. As part of that responsibility, PIs are required to understand and comply with the technical/programmatic reporting requirements of their awards, which involves becoming familiar with reporting formats, templates and any online submission portals.
Resources for submitting Technical Reports
Technical reporting requirements, including the frequency and submission instructions, should be identified in the award document. PIs have 24/7 access to their award documentation by visiting myResearch Portal. PIs should review the award documents periodically throughout the life of the project to ensure timely submission of all required reports.
Most federal sponsors require reports to be submitted/uploaded through an online portal, therefore submission of reports via email to a program officer is likely not sufficient. PIs should register/create an account for the required online portals well in advance of the first reporting due date, and periodically log in to ensure that credentials remain active. For assistance with accessing online reporting portals, PIs are encouraged to contact their College Research Office. Questions can also be referred to the federal agency’s online portal help desk.
Technical Report Reminder
The University’s Central Processing Offices (“CPO”) support PIs with their federal and federal flow-through award technical reporting obligations by sending them an automated email reminder ten (10) days after the project period end date. This email is generated from the Strategic Information Management System (“SIMS”) and the subject line contains the words “Reminder of Award Closeout Responsibilities.” This automated email reminder will also be sent to the applicable Business Area, so they can begin to assist with other final reporting requirements.
Corrective Actions for Late Technical Reports
Penn State is committed to 100% on-time reporting and takes delinquent technical reporting very seriously. Technical reports MUST be submitted at the intervals required by sponsors. Failure to submit timely technical reports can:
- Negatively impact a PI’s reputation;
- Force the University to repay some of all of the award funds back to the sponsor;
- Subject the University to legal costs due to breach of agreement; and
- Create unnecessary and costly work for University faculty and staff.
In addition, Federal regulations allow corrective actions that have a significant negative impact on PIs and the University. For example, sponsors may:
- Withhold payments to the University;
- Disallow all or part of the costs of a project;
- Suspend or terminate an award;
- Initiate suspension or debarment proceedings against the University (which could make us ineligible for Federal funding); and/or
- Withhold any additional awards and incremental funding for existing awards.
Penn State may implement the following internal corrective actions when a technical report becomes overdue:
- If Penn State is notified of a delinquency, the PI will be informed immediately. The PI will be expected to make submission of any overdue reports their top priority. Academic leadership may be engaged to ensure compliance. Non-responsive PIs may be deemed ineligible to submit new proposals as a PI or Co-PI until their delinquent report have been submitted. PIs may be asked to provide proof of submission.
- When a federal or federal flow-through technical report becomes sixty (60) days overdue, the CPO will notify the Senior Vice President for Research (“SVPR”). The SVPR reserves the right to withhold, or require the return of, any Research Incentive Funds (“RIF”) that were generated as a result of the project. Such forfeited RIF from the College, Department or PI will be returned to Central.
- PIs who demonstrate a pattern of non-compliance and late delivery of technical reports may become ineligible to be a PI. Per Penn State Policy RA03, “eligibility to serve as PI is contingent upon PIs fulfilling their responsibilities as articulated in RA02 – Stewardship of Sponsored Programs, including their responsibility to submit their reports in accordance with the terms and conditions of their awards.”
In addition, as a condition of submitting a proposal, PIs certify the following upon approval of the Internal Approval Form: “If awarded, I will administer the project in accordance with the requirements of the award as well as all applicable Penn State policies and procedures. Further, I will accept responsibility for the scientific and technical conduct of the project including the submission of any required progress or technical reports.”
Frequently Asked Questions
- What should I do if due dates change?
- Technical reporting due dates may change during the course of a sponsored project, due to no-cost time extensions or other programmatic changes. Normally, an agreement modification will be issued by the sponsor to account for such changes. Please ensure that any extensions of deadlines are properly accounted for by contacting your College Research Office.
- Technical reporting due dates may change during the course of a sponsored project, due to no-cost time extensions or other programmatic changes. Normally, an agreement modification will be issued by the sponsor to account for such changes. Please ensure that any extensions of deadlines are properly accounted for by contacting your College Research Office.
- What should I do if due dates are not listed in the award?
- Some sponsors may not list specific technical report due dates in the award document. They may instead provide the due dates to you at a later date. If you do not have the technical reporting due dates, you should contact your Program Manager / Technical Contact for more information.
- Some sponsors may not list specific technical report due dates in the award document. They may instead provide the due dates to you at a later date. If you do not have the technical reporting due dates, you should contact your Program Manager / Technical Contact for more information.
- What should I do if I cannot meet technical report deadlines?
- If you cannot meet technical report deadlines, you should first contact your Program Manager / Technical Contact to see if it’s possible to obtain a deadline extension. Your Program Manager / Technical Contact is not required, or may not have authority, to grant an extension.
If the extension request is unsuccessful, promptly contact your Department Head and/or Associate Dean for Research. They may be aware of other resources available (e.g., graduate students) to assist you. Be advised that your Department Head and/or Associate Dean for Research may, among other things, reallocate previous and future F&A cost allocations or charge a PI’s startup funds to pay for these additional resources.
- Do I need to submit technical reports if I have requested a no-cost extension?
- Yes. Unless you have written confirmation from your Program Manager / Technical Contact that your report is not due, you must submit your report by the existing deadline.
- Yes. Unless you have written confirmation from your Program Manager / Technical Contact that your report is not due, you must submit your report by the existing deadline.
As an example, National Science Foundation states that : “A ‘no cost extension’ adds time to an award, but does not relieve the awardee of reporting requirements. Annual reports are still due every 12 months. When the award finally does expire, the final report and project outcomes report are both due within 120 days.”
- What constitutes “proof” I have submitted my technical report?
- Acceptable proof of submission will depend on the type of sponsor and whether submission to an online portal is required.
- Acceptable proof of submission will depend on the type of sponsor and whether submission to an online portal is required.
If reports are required to be submitted via an online portal, PIs can either take a screenshot of the online portal reporting page that shows that the report has been submitted/received or provide a copy of the confirmation email received from an online portal after the submission.
If the award only requires a PI to submit the report via email to the sponsor, PIs can either copy their CPO on the email when they submit the report, or forward email evidence to the CPO that the sponsor has indeed received the report.
Please understand that merely stating you have submitted your report is not sufficient. If a sponsor takes compliance actions against Penn State, the university may need to demonstrate that it has validated submission of all late reports.
- I’m retiring from (or otherwise leaving) Penn State.Do I still need to worry about my technical reports, or will someone else handle them?
- It remains a PI’s responsibility to ensure proper transfer or closeout of any requirements under the award. Depending on the circumstances, some awards can be transferred to a PI’s new institution, or a “Change of PI Request” can be submitted to the sponsor for consideration. In other cases, we may need to relinquish funds back to the sponsor and provide them with a partial technical report up to the point of departure. A PI should never assume that they no longer have a responsibility to comply with the terms and conditions of the award. PIs should notify their College Research Office, Department Head and Associate Dean for Research as far in advance as possible of the departure so there is sufficient time to properly address project requirements. Department Heads will be asked to complete the Checklist for Departing Researchers.
- It remains a PI’s responsibility to ensure proper transfer or closeout of any requirements under the award. Depending on the circumstances, some awards can be transferred to a PI’s new institution, or a “Change of PI Request” can be submitted to the sponsor for consideration. In other cases, we may need to relinquish funds back to the sponsor and provide them with a partial technical report up to the point of departure. A PI should never assume that they no longer have a responsibility to comply with the terms and conditions of the award. PIs should notify their College Research Office, Department Head and Associate Dean for Research as far in advance as possible of the departure so there is sufficient time to properly address project requirements. Department Heads will be asked to complete the Checklist for Departing Researchers.
- Who can help me submit my technical reports or obtain due date extensions?
- Your College Research Office or CPO is happy to help you understand the terms and conditions of your award, including technical report due dates, but it is your responsibility as a PI to: (i) prepare and submit all technical reports (including researching how to submit your reports via online portals); and (ii) obtain written reporting due date extensions from your Program Manager / Technical Contact. Please note that any requests for project no-cost time extensions should be routed through your College Research Office, as they will need to submit an official request on University letterhead, signed by the University’s Authorized Official.
- Your College Research Office or CPO is happy to help you understand the terms and conditions of your award, including technical report due dates, but it is your responsibility as a PI to: (i) prepare and submit all technical reports (including researching how to submit your reports via online portals); and (ii) obtain written reporting due date extensions from your Program Manager / Technical Contact. Please note that any requests for project no-cost time extensions should be routed through your College Research Office, as they will need to submit an official request on University letterhead, signed by the University’s Authorized Official.
- Do I submit financial, patent or property reports to sponsors?
- Penn State Policy RA90 – Finalization and Closure – outlines the responsibilities surrounding these types of reports. Typically, PIs will only submit the technical reports to the sponsor, however they may be asked to provide input and review various forms and documentation to permit accurate and timely reporting of other types of required reports. In the event that a sponsor requires a combined technical/financial report, please coordinate this with your College Research Office.