COMPLIANCE WITH SPONSOR REQUIREMENTS

• 1.0 Purpose
• 2.0 Policy
  • 2.1 Overview
  • 2.2 Responsibility of Principal Investigator
  • 2.3 Cost Transfers
  • 2.4 Individual Effort Certification Reports
• 3.0 Definitions
• 4.0 References
• 5.0 Appovals and Revisions

1.0 Purpose

This policy describes the general guidelines for complying with research sponsor requirements.

2.0 Policy [Top]

2.1 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 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.

2.2 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.

2.3 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 Assistant Director for Research Accounting must accompany any retroactive cost transfer which is more than 60 days old. COST TRANSFERS MORE THAN 120 DAYS OLD WILL ONLY BE APPROVED IN EXTENTIATING CIRCUMSTANCES.

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

See also Procedure 8-20, "Preparation of Cost Transfers Involving Sponsored Program Accounts."

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

2.4 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, departmental administration), 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 quarterly.  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.

3.0 Definitions [Top]

4.0 References [Top]

See also Procedure 8-32, "Preparation of Effort Certification Reports."

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

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

5.0 Approvals and Revisions [Top]

       Previous version in effect from 1/15/88 to 7/6/00 available in policy archive.