Scope

This procedure supplements Procedure 1-4, Monthly Review of GM Project or Award Activity and covers the monthly review and certification of sponsored program projects and awards. The purpose of the Monthly Review of sponsored program project expenditures is to review for errors, accuracy of charges, and unusual or unanticipated charges. Any unusual transactions should be reported promptly to the Principal Investigator.

University of Virginia policy requires timely review of expenditures occurring at least once a month (by the10th working day of the month) for the previous month's activity unless approval has been granted for an alternate schedule by the University Comptroller and the Director of Audits.

University of Virginia policy assigns the principal investigator primary responsibility for the management of sponsored program funds.

Office of Management and Budget Circular A-21 (2 CFR, Part 220) requires that “the institution's financial management system shall ensure that no one person has complete control over all aspects of a financial transaction.”

Office of Management and Budget Circular A 110 (2CFR, Part 215), "Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non Profit Organizations," requires  that if the institution authorizes the principal investigator to have primary responsibility for the management of sponsored agreement funds, “then the institution's documentation requirements for the actions of those individuals (e.g., signature or initials of the principal investigator or designee or use of a password) will normally be considered sufficient.”

System References [Top]

Oracle Reports Using Discoverer

Policy [Top]

Policy I.A.1 Internal Controls
Policy II.B.2 University Reviews and Reconciliations
Policy II.C.1 Records Retention and Disposition
Policy VIII.A.6 Consistent Treatment of Sponsored Programs Costs
VIII.C.1 Compliance with Sponsor Requirements

Procedure
Procedure 1-4, "Monthly Review of  GM Project or Award Activity"

Responsibility [Top]

Fiscal Contact (Reviewer):
The department or unit fiscal person, typically listed as the fiscal contact in the integrated system for the sponsored project, is responsible for reviewing each expenditure charged to the sponsored program, Project/Task/Award combination in the University's Integrated System, to ensure its accuracy, and to ensure that sufficient source documentation, in the form of paper, or data residing in the Integrated System or supporting systems, is available.  After reviewing expenditures, the fiscal contact signs the expenditure report, as described below in this procedure, indicating that they have completed this review.  Any accounting errors or other questions about the appropriateness of a particular expense should be brought promptly to the principal investigator’s attention for clarification or correction.  With the exception of reviewing expenditures with sponsor restrictions in mind, this role is the same as the Project Reviewer described in Procedure 1-4, Monthly Review of GM Project or Award Activity.

Note: From time to time there is turnover in the fiscal contact role. To keep role data accurate in the Integrated System, changes in fiscal contact should be sent to osp-help@virginia.edu. The request should include the effective date of the change, the org to be changed and as necessary the project numbers to be changed.

Principal Investigator (Approver):
Subsequent to the review above, the Principal Investigator, PI, or other individual designated by the PI who is in a position to be knowledgeable about project expenditures, will review monthly expenditures for errors, accuracy of charges and unusual or unanticipated charges.  After reviewing expenditures, the PI approves and certifies the appropriateness of the charges.

The role of Principal Investigator is similar to the Project Manager described in procedure 1-4, Monthly Review of GM Project or Award Activity.

The PI may have someone who is in a position to be knowledgeable about project expenditures assist with reviewing the appropriateness of monthly expenditures.  While the person assisting the PI should sign the financial reports indicating to the investigator that they have reviewed and approve of the expenditures, the PI must still subsequently review and sign certifying the monthly financial reports.

In summary, for sponsored programs the fiscal contact is responsible for reviewing expenditures, and the Principal Investigator is responsible for approving expenditures. The Principal Investigator is responsible, on behalf of the University, for the sound fiscal management of the project or program in accordance with both University and sponsor requirements. Principal Investigators are responsible, to the best of their knowledge, for ensuring that expenditures are made for the intended purpose of the grant/contract in accordance with sponsor requirements as well as University policies and procedures.

Note: Unlike other GM projects and awards, in the case of sponsored programs, the Integrated System fields of Project Manager and Award Manager are reserved for Office of Sponsored Programs staff.  These roles are significantly different from other GM projects and awards and while  not covered in this procedure, it is important to understand that these roles are not the same as described in Procedure 1-4, Monthly Review of GM Project or Award Activity.

Distribution [Top]

Research Administrators
Fiscal Contact Department/ Unit Administrator
Principal Investigator

Ownership [Top]

The Assistant Vice President for Research Administration and the Director of Award Management and Accounting are responsible for ensuring that this procedure is necessary, reflects actual practice, and supports University policy.

Monthly Review

The following details the monthly review and approval responsibilities of the Fiscal Contact and then the Principal Investigator for sponsored program awards and projects.

A monthly review of PTA expenditures is an essential component of project management. Normally, the previous month’s activity for the sponsored program award and project combinations should be reviewed by the 10th working day of the month, or as detailed in an alternate schedule approved by the University Comptroller and the Director of Audits (see Policy II. B. 2, University Reviews and Reconciliations).

Fiscal Contact
The Fiscal Contact should bring any accounting errors or other questions about the appropriateness of particular expenses to the immediate attention of the Principal Investigator for clarification or correction.  Good business practices and federal regulations mandate that errors be corrected in a timely manner.  Cost transfers should be initiated as soon as the need is detected based on the monthly review and certification of sponsored program expenditures (see Cost Transfer Procedures 8-20, 8-21 and 8-22).

1. Gather and review the following information:

• prior month expenditure reports with any notations for corrections, etc.
• department records related to expenditures for this Project/Task/Award combination

2. Log on to Oracle Discoverer and run the following reports:

A.  The following report should be generated and reviewed by the Fiscal Contact. Although no signatures are required on the report, the report should be kept on file as part of the official record. The report does not need to be distributed to the Principal Investigator as the PI is to be given the PI Expenditure Detail Report described below under Section B. 

IS.FM_Expenditure Detail by Project (for review by Fiscal Contact). 
Purpose: The Expenditure detail report shows detailed expenditures by budget category along with pertinent source document reference numbers.  The report may be used to review actual and commitment expenditure transactions at the Project level and may be run for any accounting period range.

B.  The following reports should be generated, reviewed and distributed to the Principal Investigator:
 IS.FM_PI Funds available report
Purpose: Comparing Budget to Actual and Commitment Amounts at the Project level. The report is used to review the project’s funded budget balance available after considering both (1) actual project-to-date expenses, and (2) scheduled future expenses.  This report may be run for any accounting period range.

 This report should be signed and dated by the Fiscal Contact prior to distributing to the Principal Investigator. 

Note: In some situations the Fiscal Contact may know of commitments that have not yet posted to the Integrated System.  Those commitments may either be entered into the Integrated System using the manual encumbrance system of the Integrated System or a note (attachment or otherwise) may be added to the PI Funds available report.

IS.FM PI Project Detail Reports
Purpose: The PI Project Detail Reports contains three work sheets that should be run and distributed to the PI.

1. Worksheet: PI Expenditure Detail Report

Purpose: The PI Expenditure detail report shows detailed expenditures by budget category.  The report is a simpler version of the IS.FM Expenditure Detail Report and does not include commitments for future expenditures.  This report may be run for any accounting period range.

2. Worksheet: PI Planned Expense Report
Purpose: The PI Planned Expense Report shows commitments by budget category at the project level. 

3. Worksheet: PI Labor Schedule Report
Purpose:  The PI Labor Schedule report shows all present and future labor scheduled for the project/award combination based on the period you enter on the parameter screen. (Note: The report will include labor schedules from the 25th of the month prior to the period specified.)  This report has a “NOTE” in the heading to alert PIs that hourly wage is not automatically encumbered, thus those their labor commitments may not show on the Planned Expense report unless manually encumbered. 

Note: See hints on selecting parameters for printing these reports.

Note: This is the minimum number of reports needed to conduct the review activity. Many additional Predefined Reports are available in Discoverer to assist in conducting further activity analysis.

3.  To assist those performing this review, the checklist provided below has been prepared to help organize your review. This checklist is provided as a resource and does not need to be completed for each PTA combination, nor does it need to be signed or retained as a permanent record of this review. It is recommended that one printed copy be kept each month for all projects in an area, but this is not required. (If some checklist questions do not apply, simply mark them as n/a.) A printer friendly version of this checklist is also available.

4.  When conducting a review, the Oracle Discoverer reports should be printed, and all detail transactions should be checked for appropriateness, accuracy, and the existence of supporting documentation. The fiscal contact should verify that all transactions are correct and sign and date the following reports: PI Funds available Report. The fiscal contact is also responsible for following up on any transactions that remain outstanding for more than one accounting period.
Note: In some departments, different people may be responsible for different aspects of this review. Where appropriate, more than one person may sign off on the detail transactions by initialing the report next to the line item(s) they reviewed.

Projects that have no activity (meaning no transactions) during the month should be printed, signed, and dated by the fiscal contact and distributed to the Principal Investigator as usual.  In these cases, the Principal Investigator need only acknowledge receipt of the report since there are no expenditures to certify.

5.  After reviewing, signing and dating required reports, the PI financial reports are distributed to the Principal Investigator.  The Fiscal Contact should monitor to ensure that financial reports are reviewed, certified, dated and returned in a timely manner.  The PI Funds available report and the PI Expenditure detail report should be reviewed by the Fiscal Contact before distribution to the PI – only the PI Funds Available Report needs to be signed and dated by the Fiscal Contact.  The PI should review both reports and certify by signing and dating the PI funds Available Report and return both reports to the Fiscal Contact.

6.  After the PI has reviewed and signed the PI Funds Available Report, the reports and supporting documentation should be assembled and filed by PTA, or in such a manner that all material relating to a particular transaction, or accounting period, can be readily retrieved and presented when requested for audit review. These records should be maintained in accordance with the University's record retention policy.

Principal Investigator
The PI reviews the financial reports for the appropriateness of the charges, and verifies that the charges are allowable, allocable to the project, and reasonable.  Any corrections that need to be made should be brought to the attention of the Fiscal Contact who will facilitate the correction through the University accounting system. 

The PI’s certification of project expenditures is a key piece of the documentation supporting the allowability, allocability and reasonableness of project costs.  The PI certifies to the best of their knowledge that charges are appropriate.  The wording of the certification is as follows:
After review of the period expenditure detail report and this summary report, to the best of my knowledge all costs charged to this project are appropriate and salary and wages charged are in relation to work performed on this project. Where required, corrections have been or will be requested to be made in the Integrated System.

The PI may request help in reviewing certain expenditures from someone with first hand knowledge of certain expenditures such as a lab manager or another investigator on the project.  Department or unit administrators may not serve in this capacity as in most cases they do not have first hand knowledge about the appropriateness of charges to a specific sponsored program. While the person assisting the PI should sign the financial reports indicating to the investigator that they have reviewed and approve of the expenditures, University policy requires that the Principal Investigator, who has authority and responsibility for the management of the sponsored program funds, also sign and date the financial reports indicating their agreement, to the best of their knowledge, that the transactions are appropriate.

The monthly review of sponsored program expenditures by PIs should normally be completed within 30 days of the financial report being reviewed by the Fiscal Contact.  Certified reports should be returned to the Fiscal Contact for filing and retention for audit. 

WHAT TO LOOK FOR ON A GRANT AWARD

YES /  NO

NOTES AND EXPLANATIONS
WHERE ACTION IS REQUIRED

1.

Does the budget match the project budget information that you have submitted to OSP?

2.

Does total funding to projects equal my award installment?
(Contact the OSP Award Manager if there is a discrepancy)

3.

Does my award budget equal the project funding?
(Contact the OSP Award Manager if there is a discrepancy)

4.

Is re-budgeting or installment adjustment required?
If so, are there actions you need to take?

5.

Is this award, nearing its "close date"?
If so, are there actions you need to take? [See IS.FM_Award Ending Dates Report]

6.

Has appropriate documentation been retained, including receipts for purchases made with a Purchasing Card, and does it match the charges?

7.

Has all documentation been retained for non-travel and non-petty cash expenditures?

8.

Are there any unusually large or small expenditures in relation to the budget, prior months' trends, or other expectations?

A) Do you see any unexpected charges? 
If so, has follow up action been taken?

B) Are there expected charges which are NOT here?
If so, has follow up action been taken?

9.

Have all LPO's been recorded, or if not, have you contacted the purchaser for the information?

10.

Have the correct PTAEO's been used?
If not, have corrections been initiated?
[See Cost Transfer Procedure]

11.

Do you see any unallowable costs based on University procurement regulations or OMB-A21 guidelines (e.g. improper recording of equipment or salaries)?
If so, have corrections been initiated?
[See CAS Guidelines]

12.

Are travel expenses reasonable and allowable (e.g., pre-approved where necessary, lowest available fares, US air carriers, correct per diems or receipts for reasonable and actual expenses)?
Has all original documentation been sent to Procurement Services?

13.

Are petty cash expenses reasonable and allowable?
Has all original documentation been sent to Procurement Services?

14.

Have appropriate credits been recorded properly (e.g., expense transfers or credits, sales of surplus property, program income)?

15.

Have salaries been charged appropriately?
If not, have corrections been initiated through Labor Distribution?  Remember that adjustments over 90 days must be handled according to the procedure outlined in 8-22, Retroactive LD Adjustments.
[See Modifying an Existing Labor Sched]

16.

Have charges from internal service providers been recorded properly?
If not, have corrections been initiated?
[See policy VI.A.6]

17.

Is this project headed for a deficit condition?
If so, are there actions you need to take?

18.

Is this project nearing its "close date"?
If so, are there actions you need to take?
[See IS.FM_Project End Dates Report]

19.

If the PI is rebudgeting, does the sponsor allow that?  Is sponsor approval required?

20.

If cost sharing was committed to the sponsor for this project, has the Integrated System award that contains the cost share funds provided incurred costs in support of the project?

21.

If it appears that there are administrative charges (e.g. clerical/administrative salaries, office supplies, postage, etc.), are they in compliance with UVA policy?

22.

If charges on this project have been allocated, is the allocation basis documented (i.e., split between funding sources)?

23.

Does actual effort for "Key Personnel" appear to support that what was committee in the award?
If not, are sponsor notifications required?

24.

Does the NIH salary cap apply to any of these salary charges?
If so, was it properly treated?

25.

Has equipment been budgeted and approved by the sponsor (if necessary)?

26.

Are the F&A rates burdening correctly?
Have they been applied to the correct base (i.e., MTDC, TDC)?

27.

Is supporting documentation available if requested to support the charges made?

28.

Have all charges been incurred in a timely manner so as to be of a direct benefit to the project?