**INACTIVE POLICY**

For Current Policies:
Policy Table of Contents

 


                      UNIVERSITY OF VIRGINIA
           FINANCIAL AND ADMINISTRATIVE POLICIES MANUAL



TITLE:  COMPLIANCE WITH SPONSOR REQUIREMENTS      POLICY:  VIII.C.1x


Overview

In accepting a grant or contract, the University assumes
responsibility for fulfilling the program, sponsoring agency, and
State requirements.  These requirements may be specifically
contained in the agreement or they may be incorporated by reference
to guidelines issued by the sponsor in special publications or
directives.

It is essential every effort be made to assure sound management
practices and prudent fiscal policies are followed in conducting
sponsored programs.

Expenditures incurred under contracts are subject to audit. 
Expenditures incurred under grants, as well as management systems
employed by the University to administer the programs, are subject
to annual audit by the State Auditor of Public Accounts (APA).

The Federal agency appointed under the provisions of OMB Circular
No. A-88 to perform audits on the University's Federally sponsored
programs is the Department of Health and Human Services (HHS).  The
proposal for indirect costs rates to be applied to Federally
sponsored programs is subject to audit prior to negotiation of
acceptable rates by HHS.

Responsibility of Principal Investigator

The principal investigator is designated by the University to
direct the project or program being supported by the grant or
contract.

The principal investigator is responsible on behalf of the
University for the sound technical, fiscal, and administrative
management of the project or program in accordance with both
University and sponsor requirements.

Responsibilities of the principal investigator include:

      Ensuring expenditures are made for the intended purpose of
      the grant/contract and in accordance with sponsor
      requirements and University policies and procedures.

      Ensuring the budget approved by the sponsor is not exceeded.

      Ensuring necessary approval for budget reallocations has been
      obtained.


      Ensuring technical reports and other non-fiscal reports are
      properly submitted to the sponsor on a timely basis.          
            
      Ensuring grant/contract personnel have knowledge of and are 
                in compliance with the University's effort
                reporting system.

      Obtaining the necessary approvals for restricted expenditures
      such as equipment and travel.

Cost Transfers

All sponsored program charges should be correctly applied to the
appropriate ledger five account.  Cost transfers must be made
occasionally to correct errors in cost distribution.  Because
guidelines on ledger five expenditures are restrictive, every
effort should be made to promptly identify and correct such errors.

Federal regulations prohibit the shifting of costs between projects
for any of the following reasons:

      To meet deficiencies caused by overruns or other fund
      considerations.

      To avoid restrictions imposed by law or terms of the
      sponsored agreement.

     For other reasons of convenience.

The University is required to maintain records supporting charges
as required by Federal and State regulations.  Late, unexplained,
or inadequately explained transfers conflict with certifications
made at the time of the original charge.

To assure the purpose of untimely retroactive cost transfers is
properly documented, a letter to the Director of Sponsored Programs
must accompany any retroactive cost transfer which:

     is more than 30 days old if for salaries or wages,

     is more than 60 days old if for other than personal services.

     COST TRANSFERS MORE THAN 120 DAYS OLD WILL NOT BE APPROVED.

The written justification will be retained as part of the
University audit record in support of the transfer.

See also Procedure 8-30, "Preparation of Cost Transfers Involving
Sponsored Program Accounts (Ledger 5)."

See also Procedure 6-18, "Preparation of Interdepartmental Transfer
Invoices (IDT's)."

Individual Effort Certification Reports

Individual Effort Certification Reports represent the University's
system for documenting time and effort contributed to sponsored
programs, indirect cost activity, and major functions.  This system
is designed to comply with Federal government requirements as
specified in the Office of Management and Budget (OMB) Circular A-
21.

It is the responsibility of department heads to assure that
Individual Effort Certification Reports reasonably reflect the
percentage of activity applicable to each sponsored program and
function.

It is the responsibility of the Office of Sponsored Programs to
develop applicable procedures necessary to implement the Individual
Effort Certification Report System.

OMB Circular A-21 describes Individual Effort Certification Report
as follows:

      Individual Effort Certification Reports will reflect the
      distribution of activity expended by each employee covered by
      the system.

      The reports will reflect an after-the-fact reporting of the
      percentage of activity of each employee.  Charges may be made
      initially on the basis of estimates made before the services
      are performed, provided that such charges are adjusted
      promptly if significant differences are indicated by activity
      reports.

      Each report will account for 100 percent of the activity for
      which the employee is compensated and which is required in
      fulfillment of the employee's obligations to the institution. 
      The report will reasonably reflect the percentage of activity
      applicable to each sponsored agreement, each indirect cost
      category (for example, departmentaladministration), and each
      major function of the institution.

      To confirm that the distribution of activity represents a
      reasonable estimate of the work performed by the employee
      during the period, each report will be signed and dated by
      the employee or by a responsible official having firsthand
      knowledge of the work performed.

      For professorial and professional staff, the reports will be
      prepared each academic term, but no less frequently than
      every six months.  For other individuals, the reports will be
      prepared no less frequently than monthly and will coincide
      with one or more pay periods.  THESE DOCUMENTS WILL BE
      RETAINED BY OSP.                                              
                                    
      Where the institution uses time cards or other forms of
      after-the-fact payroll documents as original documentation
      for payroll and payroll charges, such documents shall qualify
      as a personnel activity report provided that they have met
      the requirements stated above.  THESE DOCUMENTS WILL BE
      RETAINED BY THE DEPARTMENT.

See also Procedure 8-31, "Preparation of Individual Effort
Certification Report."

See also Policy II.C.1, "Records Retention and Disposition."

See also Procedure 2-30, "Records Retention:  General
Requirements."

                                                                   
ISSUED BY:                                                 01/15/88

Director of 
Sponsored Programs             8.3.1.1