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Viewing: Grants Post Award Policies and Procedures

Current Status: Active PolicyStat ID: 2216369

Grants Post Award Policies and Procedures

Award Set-Up

Once a proposal is awarded, the award mechanism (letter, contract, grant, subcontract, etc.) will be forwarded to the Sponsored Research and Programs Office to the attention of the Research Administration Analyst. A copy of the proposal and budget will be sent along with the award mechanism.

The Research Administration Analyst will review the award and forward it to the Grants Accountant for account setup. After the Grants Accountant sets up the account, an E-mail with the new grant account number, name, spend categories, budget and reporting due dates will be sent to the Principal Investigator (PI), Payroll Department, Office of Financial Services (OFS), and the Office of Sponsored Research and Programs.

The Grants Accountant will set up a meeting with the PI and Research Administration Analyst to review fiscal procedures and any special requirements. If the PI has assigned a contact person 1 * other than himself/herself or the Program coordinator from whom information can be obtained or given regarding award matters, that person will also be present at the initial meeting.

The Grants Accountant will forward a copy of the award, proposal, and budget to the Staff Accountant at OFS.

Award Expenditures

Once the grant account has been established, award expenditures can take place. All award expenditures are to be sent to the Grants Accountant for review and approval. The Grants Accountant will ensure that the expenditure has an approved budget and funding within the grant Expenditures will be reviewed for unallowable costs in accordance with Uniform Guidance 2 CFR 200 (refer to Uniform Guidance 2 CFR 200 at https://www.gpo.gov/fdsys/pkg/FR-2013-12-26/pdf/2013-30465.pdf for a complete listing of allowable and unallowable costs). Requests for reimbursements must be in compliance with the CGU Reimbursement Policy as well as within the guidelines of the OMB. If the Grants Accountant determines that any expenditure request is unallowable, the request will be forwarded to the Director of Sponsored Research for further evaluation. If the Director of Sponsored Research confirms that the expenditure is unallowable, it will be returned to the PI so that a non-grant account can be assigned to the request.

Award expenditures may take place in the form of a Request for Check (RFC), Payroll, Transfer of Expense or Travel Report. The original is to be forwarded to the Grants Accountant. The original will be forwarded to OFS for processing and a scanned copy will be kept for the award electronic file.

In order for any check to be processed for payment, please submit the request as follows:

For Friday check run :Please have requests in the Grant Accountant's Office on Tuesday by 1:00 pm .

For Wednesday check run :Please have requests in the Grant Accountant's Office on Friday by 1:00 pm .

Forms

The following forms are to be used to request expenditures from grants. Copies of the forms and detailed instructions regarding how to complete them are contained in the CGU Policies and Procedures Manual. Electronic versions of the forms are available from the Treasurer's office or from the Staff Accountant at OFS.

A Request for Check is to be used when paying an invoice or requesting a reimbursement.

Complete the RFC form and attach all original receipts, invoices, and bills verifying expenses. A departmental authorized signature approving the expenses is required for payment to be processed. Forward the form and attachments to the Grants Accountant for approval.

Payroll : In order to pay all personnel on awards, the proper paper work must be filed with the Payroll Department (whether it is faculty, staff, or students). OMB guidelines require that a timesheet detailing the hours worked on the grant or a statement of work performed be submitted for all payroll.

  • Payroll documentation (such as time sheets) must be submitted to the Grants Accountant one day before the campus payroll deadline of the appropriate payroll cycle.
  • The Grants Accountant approves all payroll expenditures and forwards all payroll documentation to the Payroll Department for processing.
  • A Timesheet is required for all hourly employees and must have both the employee and the authorized departmental signature.
  • A Request for Payroll Check form may be used for individuals who are not already set up in payroll system. (Eventually the individual will need to be set up in system unless this is a one-time payment).

A Transfer of Expense Form is to be used when an expense needs to be transferred from one account to another. Typically, a transfer should only be used when an error has occurred or the grant has been over expended and the charges need to be expensed on another account. No expenses should be charged to a department's operating budget and then transferred to the grant. Nor should legitimate expenses that have already been invoiced be transferred to another grant.

Complete the form and attach the appropriate documentation and explanation for the transfer. An authorized signature from the department requesting the transfer as well as from the Director of Sponsored Research must be obtained. If the transfer is between award and non-award accounts, the form must have a Treasurer's Office signature as well.

A Travel Report is to be used for travel expenses incurred on an award.

  • Complete the form noting those expenses paid in advance by CGU versus those paid directly by the traveler. (See the Policies and Procedures Manual for complete directions on using the form.)
  • Attach all original receipts, invoices, and bills verifying expenses, including those for prepaid expenses. Expenses will not be reimbursed without original receipts.
  • An authorized signature is required from both the traveler and his/her supervisor.

Time & Effort Reporting

All employees working on a Federal Grant are required to submit time and effort reporting. The Grants Accountant will obtain from payroll a report showing the amount of salary paid and the accounts from which it was paid. This will then be used to determine the percentage of time spent on each activity. A Standard Documentation of Personnel Expenses Report will be created and sent to the PI for approval. Should the percentage of salary paid not accurately reflect the percentage of time spent on the grant, the PI will adjust the percentage, sign it and return it to the Grants Accountant.

Equipment Purchases

Equipment purchased with grant funds may, at any time, be claimed as property of the grantor. Any single item purchased over $5,000 is considered to be equipment for grants. A log of all equipment purchased with grant funds will be kept in the office of the Grants Accountant.

All computing equipment will be tagged and recorded by the Office of Information Technology. Computing Equipment should be purchased through the Office of Information Technology so that it can be tagged on arrival and set up in accordance with CGU policy. Individuals who purchase computing equipment on their own will not be reimbursed until the equipment is properly logged in by IT.

CGU does not capitalize any equipment under $25,000. Should any equipment over that limit be purchased with grant funds, the decision whether or not to capitalize it will be made in conjunction with the terms of the grant and CGU policy.

Procurement Procedures

The following procedures apply when making purchases with Federal funds:

  • Claremont Graduate University has contracted with Office Depot to provide the lowest cost on office supplies and equipment possible. Purchases will be made from Office Depot whenever possible, unless a lower price is found elsewhere.
  • Recipients will avoid purchasing unnecessary items.
  • Lease vs. purchase analysis will be done all stand alone items with costs exceeding $5,000.
  • Solicitations for goods and services will provide for all items listed in OMB A110 section 44(a)(3).

Subcontracts

CGU is responsible for ensuring that sponsor funds provided by the University to other organizations via subcontract agreements are spent in accordance with applicable laws and regulations. PIs and the Grants Accountant are to be the primary control points for allowability, allocability and reasonableness of research expenses. The following controls address this requirement.

  • The Research Administrator will ensure that a subcontractor has not been disbarred by checking the Excluded Parties Listing System at http://epls.arnet.gov . This will be done prior to submission of the proposal.
  • PI and Research Administration Analyst will assure that any necessary sponsor approvals are received before establishing the subcontract.
  • All subcontracts are to be approved by the Director of Research Administration.
  • All subcontracts will contain a clause establishing CGU's right to review all documents on site.
  • The Grants Accountant will review the A-133 report on subcontractors before the final contract is approved.
  • The Contact Person, PI and the Grants Accountant will review the invoices received from the subcontractor, and will monitor technical and programmatic activities and assure allocability, allowability, and reasonableness of costs. The subcontractor invoices should be in enough detail to determine how the funds are being used.
  • The Grants Accountant will question any costs which differ materially from the approved budget, or which appear unusual or unallowable and will withhold payment until a satisfactory explanation is received or an appropriate audit of unresolved issues can be performed.
  • Unless prior approvals are waived, the subcontractor must submit an approval to purchase equipment to the PI with a copy to the Office of Sponsored Research. Where required, the PI must obtain a written approval from the sponsor before the subcontractor can place an order for equipment.
  • The PI should be aware of the costs incurred in relation to the work performed on the subcontract and should approve all of the subcontractor's invoices.
  • Once the final invoices are paid, the Grants Accountant will complete the project closeout.

Monthly Reconciliation

A monthly reconciliation report will be generated by the Treasurer's Office and sent to both the PI and the Contact Person for their records. A monthly accounting report generated from Datatel will be sent from OFS to the Budget Officer (in most cases, this is the PI). It is the responsibility of the PI to review these for accuracy and to be prepared to request a no-cost extension if the funds will not be fully expended by the grant close date. The Grants Accountant should be contacted regarding any discrepancies or questions on either report.

Budget Revisions

The PI is to contact the Research Administration Analyst if he or she wishes to adjust the award budget.

The PI will submit a budget revision for review and approval to the Research Administration Analyst. Requests for changes will take 3 to 5 days to process. All budget adjustments must be approved by the Research Administration Analyst before expenditures can take place.

The Research Administration Analyst will determine whether or not the budget can be changed without notifying the sponsor. If the sponsor needs to be notified, the Research Administration Analyst will contact the sponsor for approval of the revised budget.

Once the revised budget has the necessary approvals, it will be forwarded to the PI and the Grants Accountant for formal changes in award account.

Cost Sharing

  1. Award

Whenever CGU or an outside agency agrees to pay a portion of the allowable costs of a sponsored project, (those costs which would otherwise be paid by the sponsor) then CGU has made a cost sharing commitment. Because cost sharing has a significant financial impact on the department providing the funds and on CGU as a whole, a decision to cost share should be carefully weighed. If funds are approved by the Dean of the School, his/her signature on the proposal sign off sheet signifies the commitment; if another unit, such as the central administration, is providing cost sharing, written documentation of the commitment must be attached to the proposal sign off sheet.

When a cost sharing commitment is agreed to, CGU is required to provide the stated resources in the performance of the sponsored agreement. Implicit in CGU's commitment to cost share is the PI's agreement to ensure that:

  • Funds are provided for cost-shared direct costs
  • Cost shared expenses for each project are accounted for in a separate account

Note: The tracking, reporting, and certifying of cost sharing are subject to audit.

B. Expenditures

To provide the most flexibility and to best support the project, it is highly recommended that the cost sharing be proposed as a lump sum amount. Cost sharing may consist of allowable direct or indirect cost resources. Some of those resources include:

  • Faculty, staff or student effort
  • General direct costs such as travel and supplies
  • Direct administrative expenses
  • Facilities expenses

C. Accounting

When a grant with a cost sharing commitment is awarded, the Grants Accountant will take the following steps:

  • Establish a grants account for the sponsored program
  • Establish an operating account (fund 211) with the same unit as the grants account. This will be the account that CGU's share of the costs on sponsored program will be recorded.
  • Set up the budget for the grants account
  • Transfer the appropriate portion of the department's salary & operating budget to the new cost sharing account
  • E-mail the PI, Dean, contact person, Program Coordinator, Budget Director, Research Administration Analyst and OFS with the above information
  • Approve all award expenditures on both the grant account and the cost sharing account using the OMB guidelines to determine allowable costs (See Award Expenditures)
  • All procedures outlined in this document apply to both the grants account and the cost sharing account
  • Records for cost sharing accounts are retained for the same period as the records for related sponsored agreement

D. Third Party Cost Sharing

All cost sharing performed on the part of a third party is to be documented and reported to CGU in accordance with the reporting dates specified in the grant.

Indirect Costs

The Federal Indirect Cost rate is negotiated periodically by the Office of Sponsored Research. Currently, for federal grants, a rate of 65.7% is used only on salaries and wages. That rate also applies to non-federal extramural funding. Should a foundation or other party specify a lower rate, however, the PI must submit a formal written policy from that institution or business defining the allowable indirect cost rate. That rate will be applied to all expenses on the grant.

Indirect costs are calculated monthly and distributed to the operating account of the department in which the PI is associated. Regardless of changes to the salary budgets, the amount of indirect costs charged may not exceed the amount budgeted unless prior approval is received from the sponsor.

Invoicing

Invoices are to be prepared either monthly or quarterly, depending on the requirements of the grant. The Staff Accountant at OFS will prepare the invoice and forward it to the Grants Accountant for review and approval. Once the invoice is approved, the Staff Accountant will submit it electronically to the sponsor. The sponsor will remit payment by either wire transfer or check. The Staff Accountant will post wire transfers to the appropriate accounts and forward a copy of the transmittal to the Grants Accountant. Checks may be deposited by either the Staff Accountant or the Grants Accountant and the Grants Accountant will maintain a copy for the file.

Reports

The Grants Accountant will send a reminder notice to the PI three months and then one month before award ends. The notice will request the PI to clear any advances and to stop any automatic transactions that charge to the award account. (payroll, phone charges, mail & duplicating expenses, etc.)

The PI prepares the final narrative and, once completed, forwards it to the Research Administration Analyst for submittal to sponsor.

The Grants Accountant prepares the final financial report once the award has been closed and all final expenses are recorded. At this time a final review of expenses will be performed to ensure that unallowable costs have not been charged to the grant. The Grants Accountant will also notify the PI if unspent funds are to be returned to the sponsor or if over expenditures need to be transferred elsewhere.

Both reports will be submitted to sponsor according to guidelines established in the award.

Records Retention

The Grants Accountant will retain the records of all grants for a minimum of three years after the award contract is complete.

Contact Information for Awards

Andrea Moore (Grants Accountant) – Post Award Grant Accountant, Review Accounting Entries, Monitor Status of Programs

Estefany Gutierrez (Grants Accountant) – Post Award Grant Accountant, Review Accounting Entries, Monitor Status of Programs

Mary Brick (Payroll Coordinator) – for questions regarding student payroll (Object Code 4080)

Rose Perez (Payroll Coordinator) – for questions regarding faculty and staff payroll. (Object Codes 4000, 4060, 4100, 4220, 4222)

Rosa Reyes (Staff Accountant) – copies of transactions that have been processed.

1 The Contact Person is the departmental personnel who will be in charge of administering the award.

Attachments:

Approval Signatures

Approver Date
Arturo Rodriguez: Assistant VP for Finance and Administration [CH] 02/2016
Carrie Herr: Enterprise Risk Management Program Coordinator 02/2016
Approver Date
Arturo Rodriguez: Assistant VP for Finance and Administration [CH] 02/2016
Carrie Herr: Enterprise Risk Management Program Coordinator 02/2016
Older Version Approval Signatures