Offered below are several practices and controls that will help ensure that sponsored projects processes are executed effectively, efficiently, and in compliance with University policies and federal regulations.
Pre-Award
- Ensure that all proposals are complete, accurate, and properly approved prior to submission, and that all proposals include the appropriate Facilities & Administration (F&A) rate or have an authorized waiver as required by University Sponsored Projects Policy 2116 – Recovery of F&A Costs.
- Regarding Cost Sharing, consider University Sponsored Projects Policy 2119 – Cost Sharing/Matching Requirements, which establishes the University’s policy of providing the minimum amount of cost sharing necessary to meet sponsors’ requirements and discourages voluntary committed cost sharing.
- Ensure that employees involved in the administration of sponsored projects have completed the appropriate training prior to the start of the project in accordance with University Sponsored Projects Policy 2140 – Sponsored Projects Certification Program.
Effort & Salary
- Compare expected and actual effort levels with committed levels to ensure they are in accordance with the terms of the grant.
- Monitor committed effort levels throughout the year and communicate to faculty when at risk for over-commitments.
- Monitor payroll activity against actual effort to allow for the timely processing of salary adjustments in accordance with University Sponsored Projects Policy 2113 – Cost Transfers and Payroll Reallocations.
- Establish a process that requires non-faculty effort to be certified by the PI, a non-PI supervisor with first-hand knowledge of the work performed, or a responsible official using a suitable means of verification that the reported effort has been expended. Suitable means of verification in this case must be in the form of a signed and dated fax, memo, letter or email from the PI attesting, after-the-fact, to the amount of effort expended by the individual.
Award Management
- Review purchase transactions to ensure that costs are allowable in accordance with Office of Management and Budget (OMB) Circular A-21. Remember, before a final determination of allowability can be determined, the following additional cost principles must also be satisfied:
- Costs must be reasonable and necessary
- Costs must be allocable to the award being charged
- Costs must be treated consistently
- Ensure that all transactions posted to an award have the approval of the principal investigator (PI) in accordance with University Sponsored Projects Policies 2110 and 2134. These policies do not require the PI to initiate or approve purchase requests but rather require the PI to document authorization of all expenditures on his/her grants. PI approval can be documented in a variety of ways, e.g.:
- Monthly fund detail statements signed and dated by the PI
- Emails from the PI to the BA certifying that monthly statements were reviewed and are accurate
- Requests for purchases directly from the PI, documented via email or in writing
- PI approval of purchase requestsEvidence of approval, in any format, must be retained and easily retrieved, typically accomplished by maintaining the documentation in the departmental grant file.
- Exercise care at the initiation of each transaction to ensure that they are charged to the appropriate fund. This will allow you to minimize the number of cost transfers performed. In the event that a transfer is necessary, provide an explanation that will satisfy future internal or federal audits by answering the following questions:
- Why was the expense originally charged to the fund from which it is being transferred?
- If the receiving fund is a sponsored project: Why should the expense be transferred to the receiving fund? (i.e., How does this charge benefit or relate to the receiving fund?)
- The PI who directs or authorizes the transfer and the BA who generates the transfer journal entry are required to certify the transfer. This can be in the form of an email, a written and signed note on the monthly statement, or captured in other documented formats, and must be maintained in the grant files (for both sides of the entry).