2146 – Stop Work Orders and Suspension of Sponsored Project Activities

1.  Any Principal Investigator (PI), Business Administrator (BA), or other individual receiving a Stop Work Order or Suspension Notice must immediately notify the Office of Research Services (ORS) and provide a copy of the order.

2. ORS will consult with applicable University offices (e.g. Penn Cener for Innovation (PCI) , Office of Clinical Research (OCR) , and Office of General Counsel OGC)), as warranted

3. ORS will notify internal and external stakeholders and update systems of record such PennERA, BEN, and RIS, to reflect any changes in terms and conditions including period of performance, deliverables, final reporting, and invoicing, as required.

4. ORS, in coordination with the PI, BA, OCR, and PCI, as warranted, will notify and send the stop work or suspension order to subawardees on any impacted award.

5. The PI and the BA are responsible for the management and administration of the sponsored project in accordance with University policy and within the constraints imposed by the Stop Work Order or suspension including:

a. Coordinating with Research Services Post Award Directors to confirm project expenditures, obligations, award balances, receivables, and freeze appropriate functionalities.

b. Identifying all activities impacted by the order or suspension, including ancillary contracts, and taking appropriate action to notify the appropriate offices of the activity, as required, including:

i. HR/Payroll Human Resources (Personnel)

ii. GSS (Personnel employed or physically present outside the US)

iii. Student Registration and Financial Services (Student employment, Graduate Student tuition, stipends, and fees)

iv. Purchasing (Independent contractors/Purchase Orders/Feeder Systems)

v. Environmental Health and Radiation Safety (Waste)

vi. University Laboratory Animal Resources (Lab Animals/Space/Equipment)

vii. Institutional Review Board (Human Subjects/ Protocols)

viii. University Service Centers

c. Identifying, reviewing, and documenting the fiscal impact of all obligations including non-cancellable obligations that cannot be terminated without incurring additional costs or penalties such as:

i. Graduate assistant tuition, stipends, and fees for the remainder of the academic term.

ii. Notice period, terminal benefits (principally accrued vacation) and/or severance for university staff on the award.

iii. Issued purchase orders that cannot be cancelled, or cancellation fees associated with those that can.

iv. Any required notice for subawards, plus their non-cancellable commitments.

v. Long-term service agreements

vi. Equipment leases

vii. Non-refundable travel and conference cancellation fees

vii. Other Penalties or cost associated with early termination or suspension.

6. Any PI, BA, or other individual receiving a notice to rescind the Stop Work Order or suspension must immediately notify the Office of Research Services and provide a copy of the notice.

7. ORS, in coordination with the PI, BA, OCR, and PCI will notify internal and external stakeholders and update systems when a notice to rescind the order or resume the work is received.

a. Systems will reflect the original termination date (or any modifications thereto) and the project will proceed in accordance with its plan. Expenses incurred during the period where the stop work order or suspension was in effect are most likely unallowable.

b. The BA must take appropriate action to update systems, and PI will resume project activities in accordance with sponsor terms and conditions.

8. ORS, in coordination with the PI, BA, OCR, and PCI will notify internal and external stakeholders and update systems when a stop work order or suspension leads to the termination of the sponsored award.

9. Closeout of the award will proceed in compliance with Sponsored Research Policies 2127, 2128, and 2129

The source of this document is Research Services.