Fiscal Grant Policies
The faculty, staff and administration of Truman State University are encouraged to obtain external funding in the form of grants for various projects and programs. This funding allows the University to carry out its objectives more adequately and to expand and enhance the variety of opportunities available in the University community. The policies shown here should establish responsibility and accountability during the grant program.
Grants for approved research and sponsored projects are the fiscal responsibility of Truman State University and are awarded to the University. The project director/project investigator is held individually responsible by the University for the proper management of the grant and for meeting the objectives of the grant. The University will ultimately be held responsible for the overall administration of funded projects. Therefore, all funds related to grants, regardless of source, shall be administered as University funds in accordance with State of Missouri law, Board of Governor policies and University policies and procedures.
Allocable Cost: A cost is allocable to a sponsored agreement if it is incurred solely to advance the work under the sponsored agreement; it benefits both the sponsored agreement and other work of the institution, in proportions that can be approximated through use of reasonable methods, or it is necessary to the overall operation of the institution.
Authorized Officials: The President and Executive Vice President for Academic Affairs of Truman State University are authorized to accept grant funding and waive indirect costs.
Effort: The amount of time spent on an activity and is expressed as a percentage of time.
Effort Reporting: Effort reporting is a purpose mandated by the federal government to verify that direct labor changes to federally approved projects/agreements are reasonable and reflect actual work performed.
Grantee: The entity receiving the money for the grant (i.e. Truman State University). Truman State University should be listed as the grantee, not the faculty/staff writing the grant proposal because they are the Project Investigator.
Grantor (also known as Awarding agency or Sponsoring Agency): The entity giving the money for the proposed grant. This is the external funding source.
Indirect Costs (also known as overhead or Facilities and Administrative (F&A) costs): Costs associated with conducting sponsored projects that are over and above the direct costs attributed to specific projects.
In-Kind Contributions: Project costs represented by services, equipment, real property or the use thereof that is donated by sponsors other than the grant award sponsor. An in-kind contribution’s value is considered to be what the cost to the University would have been if the University had paid for the item or service itself. In-Kind contributions may also include the cost share borne by the grants subcontractor.
Mandatory Cost Sharing: Cost sharing due to a written requirement of the grantor and the ability to apply for and receive the award is contingent upon the campus’ willingness to comply with this requirement. Mandatory cost sharing requirements will often be stated in the Request for Proposal (RFP), Request for Application (RFA), or Request for Quotation (RFQ). The mandatory match may be stated as a percentage of total costs, a required dollar amount, or may be required due to limitations of costs that the grantor will reimburse, such as grantors that will not pay for researchers’ salaries.
Program Income: Income earned as a result of grant-funded activity.
Project Investigator (also known as Project Director or Researcher) for Grantee: Truman State University faculty or staff member overseeing the grant operations.
Reasonable Cost: A cost may be considered reasonable if the nature of the goods or services acquired or applied, and the amount involved therefore, reflects the action that a prudent person would have taken under the circumstances prevailing at the time the decision to incur the cost was made.
Sponsored Agreement (also known as a Grant or Contract): A written agreement representing the voluntary transfer of money or property by a sponsor in exchange for the specifically enumerated performance of services, often including rights and access to results of this performance, and always including some formal financial and/or technical reporting by the recipient as to the actual use of money or property provided. The agreement is enforceable by law, and performance is usually to be accomplished under time and fund use constraints with the transfer of support revocable for cause.
Roles & Responsibilities in Award Administration
The Provost and the President are authorized to approve proposals and accept awards and amendments on behalf of the University.
The pre-award office for the University is housed in the Provost Office and consists of one Grants and Compliance Specialist and one State and Federal Compliance Coordinator.
The post-award office for the University is housed in the Business Office and consists of one Staff Accountant and one Supervisor of Accounts Payable & Grants.
Pre-Award Administrative Roles & Responsibilities:
- Assists PIs with proposals and ensures appropriate approvals are obtained prior to submission of proposal.
- Reviews proposals to ensure compliance with University, state, and federal policies and procedures.
- Assists PIs with budget revisions and/or no-cost extensions that require prior sponsor approval.
- Oversees all IRB reviews.
- Provides post-award office with grant award notifications from sponsoring agency.
Post-Award Administrative Roles & Responsibilities:
- Reviews proposals, particularly budget and budget justification, to ensure compliance with University, state, and federal policies and procedures.
- After receiving grant award notification, creates unique grant fund number in ERP financial system, loads budget in system, and notifies PI of grant fund number to be used when requesting expenses.
- Staff Accountant or Supervisor of Accounts Payable & Grants reviews all grant expenses for compliance with University, state, federal, and grantor’s policies and procedures, as well as, the grant budget. If okay, the expenditure request is then sent to Purchasing or Accounts Payable, as appropriate, for fulfillment.
- Requests and collects effort certification forms three times a year. Checks effort certification forms against payroll system charges for discrepancies over 10% of actual payroll costs per University policy.
- Processes any necessary cost transfers in accordance with Uniform Guidance regulations such as allowability, allocability, necessity, and reasonableness of cost.
- Runs process in financial system to assess allowable indirect costs to grant fund.
- On a quarterly basis, funds are drawn from the grantor agency’s website, such as NSF’s research.gov ACM$ system, after the Supervisor of Accounts Payable & Grants re-reviews the expenses for allowability, allocability, and reasonableness. Funds are drawn on a reimbursement basis.
PI Administrative Roles & Responsibilities:
- Writes the grant proposal and reaches out to Grants and Compliance Specialist for assistance with appropriate approvals prior to submission of proposal.
- PI, with assistance from grant’s Program Coordinator (when applicable), initiates the grant expenditure request, which is approved at the appropriate level (PI, dean, provost, president) depending on the amount and type of expense.
- Review effort certification forms up to three times a year and attest to the accuracy of the information on the forms by approving the forms. The PI’s effort certification form is approved by their immediate supervisor or the Dean.
- The PI, in conjunction with his/her Program Coordinator, may review the grant expenses in the financial system at any time to compare against their budget. It is expected that this review be performed on a monthly basis.
- Required to report deviations from budget and program plans, and request necessary prior approvals for budget and program plan revisions to the sponsoring agency.
- Responsible for submitting programmatic reports, as required, by sponsoring agency.
- Responsible for carrying out the activities written in the grant.
The University follows the all state and federal regulations, including those outlined in the OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (i.e. Uniform Guidance)
Purchasing Policies and Procedures
The Uniform Guidance requires full and open competition. Contractors who assist in drafting specifications for requests for proposals (RFP) must be excluded from competing for those opportunities. In addition, RFP specifications cannot have unreasonable requirements that are meant to limit competition. Also, procurements must be conducted in a manner that prohibits the use of geographical preferences in the evaluation of proposals, except in certain case where federal law explicitly requires or encourages geographic preference or when contracting for architectural and engineering services, provided that specifying geographic location leaves an appropriate number of qualified firms.
The University follows all state and federal regulations, including the procurement guidance starting in section 200.320 of the Uniform Guidance.
§ 200.320 Methods of procurement to be followed.
The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award.
(a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include:
(1) Micro-purchases —
(i) Distribution. The acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (See the definition of micro-purchase in § 200.1). To the maximum extent practicable, the non-Federal entity should distribute micro-purchases equitably among qualified suppliers.
(ii) Micro-purchase awards. Micro-purchases may be awarded without soliciting competitive price or rate quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history or other information and documents it files accordingly. Purchase cards can be used for micro-purchases if procedures are documented and approved by the non-Federal entity.
(iii) Micro-purchase thresholds. The non-Federal entity is responsible for determining and documenting an appropriate micro-purchase threshold based on internal controls, an evaluation of risk, and its documented procurement procedures. The micro-purchase threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations. Non-Federal entities may establish a threshold higher than the Federal threshold established in the Federal Acquisition Regulations (FAR) in accordance with paragraphs (a)(1)(iv) and (v) of this section.
(iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following:
(A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit;
(B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or,
(C) For public institutions, a higher threshold consistent with State law.
(v) Non-Federal entity increase to the micro-purchase threshold over $50,000. Micro-purchase thresholds higher than $50,000 must be approved by the cognizant agency for indirect costs. The non-federal entity must submit a request with the requirements included in paragraph (a)(1)(iv) of this section. The increased threshold is valid until there is a change in status in which the justification was approved.
(2) Small purchases —
(i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity.
(ii) Simplified acquisition thresholds. The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk and its documented procurement procedures which must not exceed the threshold established in the FAR. When applicable, a lower simplified acquisition threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations.
(b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate:
(1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bids method is the preferred method for procuring construction, if the conditions.
(i) In order for sealed bidding to be feasible, the following conditions should be present:
(A) A complete, adequate, and realistic specification or purchase description is available;
(B) Two or more responsible bidders are willing and able to compete effectively for the business; and
(C) The procurement lends itself to a firm fixed price contract and the selection of the successful bidder can be made principally on the basis of price.
(ii) If sealed bids are used, the following requirements apply:
(A) Bids must be solicited from an adequate number of qualified sources, providing them sufficient response time prior to the date set for opening the bids, for local, and tribal governments, the invitation for bids must be publicly advertised;
(B) The invitation for bids, which will include any specifications and pertinent attachments, must define the items or services in order for the bidder to properly respond;
(C) All bids will be opened at the time and place prescribed in the invitation for bids, and for local and tribal governments, the bids must be opened publicly;
(D) A firm fixed price contract award will be made in writing to the lowest responsive and responsible bidder. Where specified in bidding documents, factors such as discounts, transportation cost, and life cycle costs must be considered in determining which bid is lowest. Payment discounts will only be used to determine the low bid when prior experience indicates that such discounts are usually taken advantage of; and
(E) Any or all bids may be rejected if there is a sound documented reason.
(2) Proposals. A procurement method in which either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. They are awarded in accordance with the following requirements:
(i) Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Proposals must be solicited from an adequate number of qualified offerors. Any response to publicized requests for proposals must be considered to the maximum extent practical;
(ii) The non-Federal entity must have a written method for conducting technical evaluations of the proposals received and making selections;
(iii) Contracts must be awarded to the responsible offeror whose proposal is most advantageous to the non-Federal entity, with price and other factors considered; and
(iv) The non-Federal entity may use competitive proposal procedures for qualifications-based procurement of architectural/engineering (A/E) professional services whereby offeror’s qualifications are evaluated and the most qualified offeror is selected, subject to negotiation of fair and reasonable compensation. The method, where price is not used as a selection factor, can only be used in procurement of A/E professional services. It cannot be used to purchase other types of services though A/E firms that are a potential source to perform the proposed effort.
(c) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply:
(1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section);
(2) The item is available only from a single source;
(3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation;
(4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or
(5) After solicitation of a number of sources, competition is determined inadequate.
§ 200.321 Contracting with small and minority businesses, women’s business enterprises, and labor surplus area firms.
(a) The non-Federal entity must take all necessary affirmative steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible.
(b) Affirmative steps must include:
(1) Placing qualified small and minority businesses and women’s business enterprises on solicitation lists;
(2) Assuring that small and minority businesses, and women’s business enterprises are solicited whenever they are potential sources;
(3) Dividing total requirements, when economically feasible, into smaller tasks or quantities to permit maximum participation by small and minority businesses, and women’s business enterprises;
(4) Establishing delivery schedules, where the requirement permits, which encourage participation by small and minority businesses, and women’s business enterprises;
(5) Using the services and assistance, as appropriate, of such organizations as the Small Business Administration and the Minority Business Development Agency of the Department of Commerce; and
§ 200.322 Domestic preferences for procurements.
(a) As appropriate and to the extent consistent with law, the non-Federal entity should, to the greatest extent practicable under a Federal award, provide a preference for the purchase, acquisition, or use of goods, products, or materials produced in the United States (including but not limited to iron, aluminum, steel, cement, and other manufactured products). The requirements of this section must be included in all subawards including all contracts and purchase orders for work or products under this award.
(b) For purposes of this section:
(1) “Produced in the United States” means, for iron and steel products, that all manufacturing processes, from the initial melting stage through the application of coatings, occurred in the United States.
(2) “Manufactured products” means items and construction materials composed in whole or in part of non-ferrous metals such as aluminum; plastics and polymer-based products such as polyvinyl chloride pipe; aggregates such as concrete; glass, including optical fiber; and lumber.
(c) Federal agencies providing Federal financial assistance for infrastructure projects must implement the Buy America preferences set forth in 2 CFR part 184.
Indirect (Facilities and Administrative) Cost Recovery
Indirect costs include the University’s general operating expenses that are incurred in support of sponsored activities. For example, buildings, use of equipment that is not purchased by sponsored project budgets, operations and maintenance of facilities, libraries, and administrative support costs (accounting, purchasing, facilities management, etc.).
Most funding agencies recognize the existence of indirect costs and have policies in place to provide for their funding. Truman negotiates indirect cost rates with our responsible federal auditing agency (Department of Health and Human Services), and the negotiations are based upon documented university spending on activities in support of sponsored programs. It is the University’s policy to recover the maximum amount of indirect cost allowable by the funding agency that is consistent with successful grant applications. It is the responsibility of the proposal writer to include indirect costs in the grant proposal. If the sponsoring agency does not allow indirect costs, or allows indirect costs less that Truman’s current rate, then project director must attach documentation requesting a non-standard rate and gain advance approval in writing from the President or Executive Vice President for Academic Affairs. Project Investigators do not have authority to make financial commitments to potential sponsors.
The University’s current indirect cost rate agreement can be found by clicking here.
Contracts or grants from commercial firms are expected to provide for recovery of full indirect costs (i.e. Facilities & Administrative). Except where explicitly limited by federal statute or other standard written sponsor policy, contract or grant proposals to non-commercial sponsors must include full applicable indirect costs in the proposal budget. In some cases, sponsor policies will limit administrative costs without limiting facilities costs. In those instances, a University contribution toward the administrative costs may be made without a contribution toward the facilities costs.
Cost Sharing and Matching
Cost sharing or matching is the portion of project or program costs not borne by the sponsoring agency. Cost sharing is the process of incurring and documenting direct costs relating to a project that are not reimbursed by a sponsoring agency. Cost sharing is normally a cost paid by the University, but any funding outside of the grantor’s and the University’s funding may count as cost sharing, provided it is stated and approved in the grant proposal documentation. Two primary types of cost sharing are mandatory cost sharing and voluntary committed cost sharing, which are defined in the definition section of this policy. All cost sharing must be recorded in the University’s computerized financial system, if it is part of the negotiated grant agreement.
All matching and cost sharing resources must meet the following general criteria:
- They must be verifiable from the University’s accounting records
- They may not be included as contributions for any other federally assisted project or program in either the current or any prior period
- They must be necessary and reasonable for proper and efficient accomplishment of project or program objectives
- They must be allowable under the applicable cost principles.
- A matching contribution must be for something for which the organization or institution could have spent federal funds.
- They must be provided for in the approved project budget.
Unrecovered indirect costs may also be included as part of cost sharing and matching, with the prior approval of the awarding agency. Some sponsoring agencies prohibit this.
Cost sharing and matching met with cash outlays must be from non-federal sources and the outlay must benefit the funded project in some fashion.
For cost sharing and matching met with in-kind contributions, the University must:
- Assert a value of the service or asset provided (current fair market value)
- Volunteer Services-value at a rate consistent with those paid for similar work in the University (the rate should be based on the TYPE of work, not the skill level of the volunteer)
- Donated Supplies-use the fair market value for the supplies, but be careful to base that valuation on the condition and quantity of the assets received.
- Donated Space-use the fair rental value, established by an independent appraisal.
It is the Project Investigators responsibility to ensure that cost sharing is approved by the appropriate person during the proposal, as well as, to periodically follow up with the Staff Accountant or Supervisor of Accounts Payable & Grants regarding the tracking of cost share expenses throughout the life of the grant.
Review and Approval of Revisions of Budget and Sponsored Project Plan
Project Investigators are required to report deviations from budget and program plans, and request prior approvals for budget and program plan revisions to the sponsoring agency. Approval must be obtained from the Program Director, or other authorized official, with the grantor agency.
Prior approvals must be requested from sponsoring agencies for one or more of the following program or budget related reasons.
- Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval).
- Change in a key person specified in the application or award document.
- The absence for more than three months, or a 25 percent reduction in time devoted to the project, by the approved Project Director or Project Investigator.
- The need for additional funding.
- The transfer of amounts budgeted for indirect costs to absorb increases in direct costs, or vice versa, if approval is required by the awarding agency.
- All pre-award costs are incurred at the recipient’s risk (i.e., the Federal awarding agency is under no obligation to reimburse such costs if for any reason the recipient does not receive an award or if the award is less than anticipated and inadequate to cover such costs).
- Programmatic reasons may require the period of performance of a grant or contract to be extended with no additional funding from the sponsor. This action is called a No-Cost Time Extension and is typically up to 12 months in length. This time extension must be requested of the sponsor. They do not happen automatically.
Truman’s Supervisor of Accounts Payable and Grants should be notified of any budget changes as soon as the sponsoring agency approves the change.
Most approvals for budget revisions come in the form of e-mails either from the PI (if prior approval is not needed from the sponsoring agency) or an e-mail from the sponsoring agency (when prior approval is required).
Ensuring Costs Charged to Grants are Allowable, Reasonable, and Allocable
§ 200.403 Factors affecting allowability of costs.
Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also § 200.306(b).
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3).
§ 200.404 Reasonable costs.
A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to:
(a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award.
(b) The restraints or requirements imposed by such factors as: sound business practices; arm’s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award.
(c) Market prices for comparable goods or services for the geographic area.
(d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government.
(e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award’s cost.
§ 200.405 Allocable costs.
(a) A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. This standard is met if the cost:
(1) Is incurred specifically for the Federal award;
(2) Benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods; and
(3) Is necessary to the overall operation of the non-Federal entity and is assignable in part to the Federal award in accordance with the principles in this subpart.
(b) All activities which benefit from the non-Federal entity’s indirect (F&A) cost, including unallowable activities and donated services by the non-Federal entity or third parties, will receive an appropriate allocation of indirect costs.
(c) Any cost allocable to a particular Federal award under the principles provided for in this part may not be charged to other Federal awards to overcome fund deficiencies, to avoid restrictions imposed by Federal statutes, regulations, or terms and conditions of the Federal awards, or for other reasons. However, this prohibition would not preclude the non-Federal entity from shifting costs that are allowable under two or more Federal awards in accordance with existing Federal statutes, regulations, or the terms and conditions of the Federal awards.
(d) Direct cost allocation principles: If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then, notwithstanding paragraph (c) of this section, the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Where the purchase of equipment or other capital asset is specifically authorized under a Federal award, the costs are assignable to the Federal award regardless of the use that may be made of the equipment or other capital asset involved when no longer needed for the purpose for which it was originally required. See also §§ 200.310 through 200.316 and 200.439.
(e) If the contract is subject to CAS, costs must be allocated to the contract pursuant to the Cost Accounting Standards. To the extent that CAS is applicable, the allocation of costs in accordance with CAS takes precedence over the allocation provisions in this part.
Unallowable Cost Treatment
An unallowable cost mistakenly charged to a federally-funded award would either be identified during a review of expenses by the PI with his/her program coordinator or by the Staff Accountant or the Supervisor of Accounts Payable & Grants when preparing the quarterly draw.
The Staff Accountant or Supervisor of Accounts Payable & Grants ensures unallowable indirect costs are not included in the indirect cost rate calculations by confirming the expense account of all expenses and comparing the automatically generated calculation to a manually calculated indirect cost rate based on each type of expense.
The PI and Program Coordinator are the first line of defense to confirm proposed costs are reasonable, allocable, and allowable before the expense is incurred. In addition, expenses are submitted via a requisition or contract process and reviewed by either the Staff Accountant or the Supervisor of Accounts Payable & Grants.
Unallowable direct and indirect costs would be charged to the applicable department’s education and general fund (i.e. 1110).
An unallowable direct cost mistakenly charged to a federally-funded project would be corrected via an accounting journal entry in the financial system by either the Staff Accountant or the Supervisor of Accounts Payable & Grants as soon as possible. The expense would be transferred out of the grant fund to a University general fund.
Budget & Expenditure Monitoring
It is the responsibility of the PI to ensure grant funds are used in a reasonable, allocable, and allowable manner. It is also the responsibility of the PI to ensure the grant expenses don’t exceed the grant budget. It is recommended the PIs maintain an internal spreadsheet for tracking grant activity and compare those records to the activity in the University’s financial system on a monthly basis.
As expenses come through, they are also reviewed by the Staff Accountant or Supervisor of Accounts Payable & Grants to ensure budgeted funds are available within the grant to cover the expenses. Within the University’s financial system, the budget is input by the Business Office, usually the Supervisor of Accounts Payable & Grants. See expenditure approval procedures below for additional details. The Staff Accountant or Supervisor of Accounts Payable & Grants review grant activity as expenses come through and most grant funds are invoiced on at least a quarterly basis, so the grant budget status is also reviewed at that time.
The financial information from one funding source to another is segregated based on a unique fund number. Each grant award receives its own unique fund number. The Supervisor of Accounts Payable & Grants creates new accounting elements, as needed, for the financial system for tracking grant expenditures. The Supervisor of Accounts Payable & Grants notifies the PI and the Program Coordinator of their unique fund number, so grant activity is immediately charged to the appropriate fund number. The Staff Accountant or Supervisor of Accounts Payable & Grants also confirms the accounting string is correct, including the fund number, with the review of each expense transaction.
Expenditure Approval Procedures
The Staff Accountant or Supervisor of Accounts Payable & Grants reviews award-related expenditure requests for compliance with federal OMB cost principles.
The University uses both purchase orders and purchasing cards for procurement needs. Only certain full-time employees are authorized to have a purchasing card. Before receiving a purchasing card, the employee must go through an online training, complete a test over the training materials, and get approval from their appropriate Vice President within the University.
Purchase order requests require a departmental requisition that is initiated by the PI which is approved at the appropriate level (PI, Dean, Provost, President). The requisition provides information regarding what the expense is and a business purpose. Proper backup documentation such as a vendor quote must be attached. The Staff Accountant or Supervisor of AP & Grants reviews the expense for reasonableness, allocability, and allowability. Then, the purchase order request is provided to Purchasing. Purchasing, in compliance with appropriate policies, determines if a bid process is required. If a bid is required, then Purchasing goes through the proper purchasing procedures, awards the bid to the appropriate vendor, creates the purchase order and sends it to the vendor. If no bid is needed, Purchasing creates the purchase order and sends it to the vendor. The paperwork is then provided to Accounts Payable. Once an invoice is received and the department confirms receipt of the goods or services, Accounts Payable processes payment.
Check or expense reimbursement requests require a departmental requisition that is initiated by the PI which is approved at the appropriate level (PI, dean, provost, president). Reimbursements to the PI must be approved by their Department Chair or the Dean. The requisition provides information regarding what the expense is and a business purpose. Proper backup documentation such as an itemized receipt or invoice must be attached. In the case of speakers or independent contractor arrangements, there are University-created contracts that are used as backup documentation for those types of expenses, along with an IRS W-9 tax form. The Staff Accountant or Supervisor of AP & Grants reviews the expense for reasonableness, allocability, and allowability. Then, the check request is sent to Accounts Payable for processing.
Payroll transactions require a proper payroll contract with proper approvals, such as the PI, Dean, Provost, or President (depending on amounts and type of employee). Payroll contracts differ based on the type of employee (student versus faculty/staff) and the amount of the payment. Payroll transactions for the PI are approved by the their immediate supervisor or the Dean. Then, the Staff Accountant or Supervisor of AP & Grants reviews the expense for allowability based on the grant budget.
Travel expense reimbursements require a travel expense report be completed, and itemized receipts for all expenses over $25 (excluding mileage) be provided. The travel expense report is approved by the PI, and if needed, the Dean or Provost (depending on amounts). Reimbursements to the PI must be approved by their immediate supervisor or the Dean. The Staff Accountant or Supervisor of AP & Grants reviews the expense for reasonableness, allocability, and allowability. Then, the check request is sent to Accounts Payable for processing.
Credit card purchases are approved by the PI and/or Dean. During the bi-monthly upload of credit card expenses into the financial system the Supervisor for Accounts Payable & Grants reviews the expense for reasonableness, allocability, and allowability. Monthly, the cardholder is required to submit their statement with appropriate approvals, along with their receipts and business purpose for each expense. The monthly credit card statement is audited by the Staff Accountant to confirm compliance with University purchasing policies.
Equipment is defined as items of non-expendable tangible personal property having a useful life exceeding one year and a unit acquisition cost exceeding $5,000. For sponsored projects, items costing under $5,000 will be considered supplies. The award budget must clearly allow for the purchase of equipment before the purchase will be processed, and any equipment should be received at least 90 days prior to the grant’s expiration date.
Minimum standards for the management of equipment purchased with federal funds include the following:
The University is to use the equipment for project purposes as long as it is needed whether or not the project continues to be supported by the federal government. When not needed for the original project or program, equipment may be used in connection with other federally sponsored activities with a priority for those activities sponsored by the federal awarding agency that funded the original project. There is also nothing to preclude the use of equipment purchased with federal funds on other projects or programs which are not federally funded so long as it will not interfere with the work on the project or program under which the equipment originally was acquired. When acquiring replacement equipment, the recipient may use the equipment to be replaced as trade-in or sell the equipment and use the proceeds to offset the costs of the replacement equipment subject to the approval of the Federal awarding agency.
Equipment records must be maintained on all grant-acquired equipment and all federally owned equipment:
- Description of the equipment
- Manufacturer’s serial number, model number, federal stock number, national stock number, or other identification number
- Source of the equipment including the award number
- Whether title vests in the recipient or the federal government
- Acquisition date or date received if the equipment was furnished by the federal government and costs if purchased by the recipient
- Information which would permit the calculation of the percentage of federal participation in the cost of the equipment
- Location and condition of the equipment and date the information was reported
- Unit acquisition cost
- Ultimate disposition data including date of disposal and sale price or method used to determine fair market value where a recipient compensates the federal awarding agency for its share of the residual amount.
A physical inventory of equipment must be taken and the results reconciled with the equipment records at least once every two years. The inventory process must verify the existence, current utilization, and continued need for equipment. Any loss, damage or theft must be promptly investigated and fully documented and, if the equipment is owned by the federal government, the recipient must promptly notify the awarding agency. Maintenance procedures must be in place to keep equipment in good working order.
Program income should be used in a manner consistent with program and project purposes and should be expended in accordance with federal regulations. Reporting of the program income is done in accordance with the requirements of the award either as an addition to the award, cost-sharing on the project, or as a deduction from the award.
It is the responsibility of the Project Investigator to verify the effort of all personnel related to his/her sponsored project.
For all sponsored projects with salary expenses, a report will be provided to the Project Investigator on a semi-annual basis to review the salary expenses and percentages charged to a particular grant since the last report. The Project Investigator should review the report and send an e-mail or a signed copy of the report to the Staff Accountant certifying that the expenses are correct or listing any corrections that are needed. If there is a correction to be made, Payroll will be notified via e-mail.
This quarterly certification form is required as a means of documenting 100% effort for those personnel whose salary or wages has been either directly charged to grants and contracts, paid from other funds where it has been identified as cost sharing, or paid from other federal sponsored funds.
A cost overrun occurs when the total costs recorded in the grant fund (4 to 6 digit identifying number for the grant project) exceed the total budgeted for the project period. If future funding has been awarded, and this is only a matter of timing, no action is necessary. If the overrun is determined to be an error, the excess expenditures need to be identified and transferred to another fund, such as a University department, which will be identified by the Office of Academic Affairs.
The Project Investigator is primarily responsible for monitoring the grant to ensure that cost overruns do not occur and if they do he/she is responsible for initiating corrective action. The Staff Accountant or Supervisor of AP and Grants will monitor the grant fund and notify the Project Investigator if they are near or at their budget limit. However, the Project Investigator should reconcile their expenses with the University’s financial system on a monthly basis because they are ultimately responsible for grant staying within its budget.
Reconciling Grant Funds
All financial activity related to a sponsored project shall be reconciled on a monthly basis to ensure that expenditures and revenues are within appropriate limits and guidelines. All expense corrections should be made within 90 days of the activity date. Contact the Staff Accountant or Supervisor of Accounts Payable and Grants to make corrections. More information on limits and guidelines can be found on the appropriate grantor agency websites and in the OMB’s Uniform Guidance.
Financial records, supporting documents, statistical records, and all other records pertinent to an award shall be retained for a period of three years from the date of submission of the final expenditure report or, for awards that are renewed quarterly or annually, from the date of submission of the quarterly or annual financial report, as authorized by the federal awarding agency.
- When litigation, claim, or audit is started before the expiration of the three-year period, records must be maintained until everything is resolved and final action is taken. Records for real property and equipment shall be retained for three years after final disposition.
- Indirect cost (F&A) rate proposals, cost allocation plans, etc. may have three-year retention periods with different start dates if the rates are, or are not, submitted for negotiation
- Technical and programmatic data (research data) is typically defined as information, regardless of form or the media on which it may be recorded, including computer software. In practice, scientific data generally is defined to include material contained in laboratory notebooks or other media such as computer disks and machine printouts and includes both intangible data (ex. Statistics, findings, conclusions) and tangible data (ex. Notebooks, printouts). Retention of this data is generally delegated to the Project Investigator. The Project Investigator should hand over this data to the University if they leave the institution.
Participant Support Costs
Participant support costs means direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects. The Uniform Guidance requires prior approval of the Federal Agency in order to incur Participant Support Costs under federally sponsored awards. The Participant Support Costs must be incurred within the period of performance of the project and be specifically allowed by the sponsoring agency.
A participant is defined as a non-employee who is the recipient, not the provider, of a service or training associated with a workshop, conference, seminar, symposium or other short-term instructional or information sharing activity. Participants do not perform work or services for the project or program unless it is for their own benefit. Participants may include students, scholars, and scientists from other institutions, representatives from the private sector, teachers, and state or local government agency personnel.
Participant Support Costs do not include honoraria for guest speakers, expenses for the PI, project staff or collaborators to attend project meetings, conferences, or seminars, payments to GRAs, or payments made to research subjects as an incentive for recruitment or participation in a research project.
Participant Support Costs should be tracked using account or activity codes. Any rebudgeting of Participant Supports Costs to another budget category requires the approval of the Federal agency.
Participant Support Costs Supporting Documentation
For stipend or subsistence allowances paid to participants, an approved requisition is required that lists the name of each participant and the amount each participant is to receive. The requisition must reference the unique fund number representing the appropriate grant to be charged. The Principal Investigator and/or Dean of the PI must approve the expense. In addition, a statement/memo is needed explaining that the student(s) are eligible to receive the amount as a participant of the program.
Travel and registration/membership fees paid to or on behalf of participants require a requisition, or an approved University credit card holder may also incur the travel expense. The requisition or credit card expense must reference the unique fund number representing the appropriate grant to be charged. In either case, the Principal Investigator and/or Dean of the PI must approve the expense. Itemized receipts, invoices, or billing statements marked paid are required as backup documentation for any expenses exceeding $25.
For meal expenses paid to or on behalf of participants as part of a workshop, an approved requisition is required, or an approved University credit card holder may also incur the meal expense. The requisition or credit card expense must reference the unique fund number representing the appropriate grant to be charged. In either case, the Principal Investigator and/or Dean of the PI must approve the expense. In addition, an attendee list, the meal receipt, and business purpose are needed.
ACM$ Drawdown Procedures – This Information is Specific to NSF Awards
How the dollar amounts to draw from ACM$ are calculated? The Supervisor of Accounts Payable & Grants runs an automated process in the financial system that posts the receivable balance as of the end of a given month. On approximately a quarterly basis, the Staff Accountant or the Supervisor of Accounts Payable extracts the expense transaction details for the period being requested. The expenses are reviewed for allowability, allocability, and reasonableness. The total of the expenses is compared to the receivable balance to confirm it matches. A copy of the expense detail and a request to draw down the funds from the NSF is given to the University Comptroller for approval before a draw down of the funds occurs.
Who prepares the ACM$ drawdown? Supervisor of AP & Grants
Who reviews the ACM$ drawdown? Both the Supervisor of AP & Grants and the University Comptroller prior to the drawdown. In addition, the Assistant Comptroller, confirms receipt of the approved drawdown amount in the appropriate bank account and notifies the cashiers office, so they can appropriately receipt the funds against the grant receivable.
Who certifies the ACM$ drawdown? Supervisor of AP & Grants
Who submits the ACM$ drawdown? Supervisor of AP & Grants
Questions about this policy should be addressed to the Staff Accountant (Zeb Riney) or Supervisor of Accounts Payable and Grants (Angela Carron). Individuals wishing to recommend changes to the policy should contact the University Comptroller.