All federal contracts are set up in Sponsored Project Accounting (SPA) funds and follow normal post-award processing through OSRS/SPA. Federal F&A rates will apply.
Contracting Officer’s Authorizations (COAs)
After a federal contract is fully executed, there may be a need to request permission from the federal Contract Officer for certain activities. Requirements for prior authorization vary by award, agency, and even Contract Officer. At the University, these requests are generally submitted by the department but ResearchContracts@wusm.wustl.edu should be copied on all such communications. It is very important to receive a COA where applicable, as it will keep all activities compliant with the contract terms and conditions, and will prevent future penalties and corrections at a later date.
Examples of items or actions that may need COAs include, but are not limited to:
- Deviations from scope of work or budget
- Issuing Subcontract Agreements of any kind (i.e., Consultants, Subcontracts, or Purchased Services), including all amendments to these agreements
- Patient care costs
- Accountable Government Property: non-expendable personal property >$1,000 and “sensitive items” (supplies/equipment highly desirable and easily converted to personal use)
- Addition/change of personnel
- Acquisition of any interest in real property
- Special rearrangement or alteration of facilities
- Purchase or lease of any item of general purpose, office furniture, or equipment regardless of dollar value.COAs are not used to authorize modifications to the contract for additional funds, extensions or deliverables. Instead, a full contract amendment will need to be requested for these actions.
Close out activities (invention and equipment reporting, etc.)
Negative Invention Reports will be signed by JROC and should be forwarded to ResearchContracts@wusm.wustl.edu. JROC will route the report to the sponsoring agency.
Positive Invention Reports should be submitted to the Office of Technology Management (“OTM”) (See https://otm.wustl.edu/for-innovators/licensing-process/).
Equipment Reports and Release of Claims are signed by Sponsored Projects Accounting (“SPA”).
- All subawards for federal contracts should be submitted using the SUBSystem.
- JROC should be notified during award stage if any subcontracts are planned or expected.
- Reminder –the department must obtain government approval before subcontracting, via the COA process (see above).