Are subcontractors required to submit labor detail reports with invoices to the primary Awardee Institution?

A prime recipient is responsible for justifying and supporting all billed items, amounts and categories to PCORI, which may or may not involve labor reports from subcontractors. The prime must ensure that the flow-downs of PCORI’s contract have been properly communicated in the performance of all work related to the project. Although subcontractor labor detail is not required at the time of invoice submission, PCORI may request certification documentation during a financial compliance review.

Can I reallocate funds between certain budget categories without prior approval? 

PCORI contracts allow reallocation of funds between certain budget categories without prior approval, provided the total award is not overspent. However, the invoice budget should always match the latest fully executed budget, to allow for accurate tracking of balances and help determine whether a modification may be necessary. For questions regarding your contract budget please contact your contract administrator.

Can I submit more than one invoice for the same billing period?

Yes, you may submit more than one invoice for the same billing period if expenses were missed on the original submission. Please ensure that the billing period entered in PCORI Online matches the billing period on the physical invoice attached to the submission. Note that PCORI Online will show a warning message alerting the user that an invoice for the same billing period has already been submitted; however, the system will not prevent the user from submitting the invoice.

Can Research, Supplemental Funding and Peer Review expenses be invoiced together in one submission through PCORI Online?

All funding categories can be invoiced at the same time in one submission through PCORI Online. The system has three designated boxes/areas for entering Research, Supplemental Funding and Peer Review expenses. However, the billing period can only be entered once in the system per submission; therefore, if the billing periods of the three funding categories differ, this should be noted on the actual invoice(s) or in a separate note uploaded along with the invoice submission.

Does PCORI require effort certification reporting?

Awardees must follow their institutional policies regarding effort certification. Although effort certification is not required at the time of invoice submission, PCORI may request certification documentation during a financial compliance review.

How do I submit invoices to PCORI? Does PCORI provide any resources to financial officers on submitting invoices?

Invoices must be submitted through the PCORI Online system located at: https://pcori.force.com/engagement.

Resources for Financial Officers include:

  • The Financial Officer Welcome Guide provides information on creating a PCORI Online account, general invoice submission information and contact information for invoice-related questions and assistance.
  • The PCORI Online Resources for Awardees page provides links to PCORI Online user manuals and recorded training sessions on how to upload and submit invoices to PCORI for review and payment.

How do I submit the final invoice?

All invoices, including the final invoice, should be submitted by the financial officer through PCORI Online for review and payment. When submitting each invoice, you will be asked to select “Yes” or “No” to indicate if the invoice is your final invoice. Select “Yes” if you anticipate the invoice to be the final invoice submitted for the entire project, including Peer Review (if applicable).

How do qualifying expenses on an award get paid?

Unless specified otherwise in the research award contract, recipient institutions must submit invoices no less than every 90-days detailing charges to each approved budget category. Invoices must be supported by a labor detail report reflecting the salary for all personnel charged to the project. 

For fixed-price awards, invoices should be submitted based on the milestone and payment schedule found in the contract, with payments typically occurring upon contract execution and when a report is due.

Invoices are paid within 30 days of submission to PCORI via ACH method if the invoice conforms with the contract terms and conditions. Payment may be withheld, or the invoice returned, if the awardee institution fails to provide the detail and support the contract requests, fails to justify an expense questioned by PCORI, or invoices for a milestone that has not been achieved per the milestone and payment schedule in the contract.

Invoices must be submitted through PCORI Online, which can be accessed through .https://pcori.force.com/engagement

How should awardees bill personnel effort on invoices to PCORI?

Only the actual level of effort should be billed to PCORI. For example, if a particular position is budgeted at 10 percent effort and the researcher spends 15 percent effort on the project in the first month and 5 percent in the second month, then the recipient institution would report it exactly as 15 percent and 5 percent.

If an institution is subject to the Single Audit, or its financial statements are audited annually and it has effort certification controls in place, is the institution still required to submit labor detail with each invoice?

Yes, all awardees requesting salary and fringe benefits are required to submit labor detail with invoices.

If an institution’s system-generated invoice does not include all of the cost categories PCORI requires, is a system-generated invoice still required to be submitted?

Yes. All invoices submitted to PCORI must contain all cost categories outlined within the contract. If a standard system-generated invoice does not capture the needed information, then an institution must populate the Sample Invoice Template provided by PCORI on the Awardee Resources page. The institution must also provide its system-generated invoice for cross-validation.

In place of a financial official, is an (authorized) administrative official’s signature acceptable on invoices submitted to PCORI?

Yes, an (authorized) administrative official’s signature or explicit indication of approval is adequate.

Is a final expenditure report required?

PCORI considers the final invoice to be the final expenditure report and does not require an additional report.

What are some common reasons invoices are rejected?

Common reasons PCORI will reject an invoice and require resubmission include:

  • Cumulative Discrepancies - Invoices are rejected when the cumulative expense to date on the awardee invoice does not agree with PCORI’s records (within $5.00). Any prior period adjustments or reallocations of expenses already paid should be reported to PCORI so that records can be updated.
  • Missing Invoices / Gaps in Invoicing - PCORI holds or rejects invoices if there are prior periods that have not been invoiced. If a prior period invoice has not been submitted, PCORI notifies awardees and allows one week for submission of the missing invoice before rejecting the current invoice. To avoid gaps in invoicing, the start of a billing period should always be the day following the end of the previous billing period.
  • Missing Labor Detail – Invoices are rejected for cost reimbursable research contracts if labor detail is not provided.
  • Overspent Budget - Invoices are rejected if the cumulative contract expenses exceed the approved contract budget.

What if an institution considers salary information as confidential information that cannot be shared with outside organizations?

The labor detail should then be submitted to show title and rate (rather than name). The invoice will be verified against the approved budget detail in the executed contract. 

What is the best way to ask questions or address invoicing concerns? 

There are several ways to get in touch with us: 

  • For questions related to invoicing, you may call us at 202-370-9315 or email [email protected]
  • For technical troubleshooting, such as creating/updating an account, or issues with the PCORI Online system, email [email protected] for immediate assistance. 

What should we do when no expenses have been incurred during an invoice period? 

If no expenses have been incurred during an invoice period, PCORI asks that awardees submit a $0 invoice reflecting this to fulfill the invoicing frequency requirements outlined within the contract and to allow PCORI to maintain accurate financial records. 

Will PCORI accept a revised final invoice if an awardee realizes the original final invoice did not include all costs? 

PCORI will accept a revised final invoice if submitted via PCORI Online within 90 days of the contract term date. Invoices submitted after 90 days of the contract term date will be evaluated on an individual basis. In cases where the award has been financially closed, revised final invoices submitted more than 90 days after the contract term date may not be paid. 

How often must invoices be submitted? 

Please refer to the contract terms and conditions. 

My institution does not have an audited indirect cost rate. Can we ask for indirect costs? 

Institutions without a federally negotiated or audited rate can request a de minimus rate of 10 percent of the allowable direct costs. See the Submission Instructions and PCORI Cost Principles for a description of allowable direct costs under a PCORI award. 

My institution received a provisional indirect cost rate, or has a new indirect cost rate, that is different from what was proposed at the time of award. What do I need to do? 

Applicants must adhere to the cost rate used in the application. 

When is the final invoice due? 

PCORI must receive the final invoice within 90 days of the contract term date. In addition, please refer to the terms and conditions of the contract.


Posted: November 16, 2023

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