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