Procedure: 8-15

Effective: August 1, 2004

Owner: Assistant Vice President for Research Administration in the Office of Sponsored Programs

Latest Revision: April 25, 2007

Scope

This procedure covers the application of expenditure controls to sponsored program awards and projects, and the distribution of transaction control information to departments.

System References [Top]

Proposal Approval Sheet
Sponsored Program Notice of Award
Transaction Control Template – Federal Awards
Transaction Control Template – Subcontracts
Transaction Control Template – Fellowships and Training Grants
CAS Exceptions Supplemental Form

Policy [Top]

VIII.A.6 Consistent Treatment of Sponsored Programs Costs
VIII.C.1 Compliance with Sponsor Requiremements
VIII.C.1A Compliance with Federal Sponsore Requirements

Responsibility [Top]

The Director of Accounting and Award Management in the Office of Sponsored Programs is responsible for ensuring the application of transaction controls to sponsored research awards according to this procedure and to the relevant and applicable regulations governing the charging of direct costs to such awards.

Distribution [Top]

Office of Sponsored Programs Administrators
Associate Deans
Fiscal Contacts
Research Administrators

Ownership [Top]

The Assistant Vice President for Research Administration in the Office of Sponsored Programs  is responsible for ensuring that this procedure is necessary, reflects actual practice, and supports University policy.

Procedure Steps

These procedures apply to all grant and contract projects established on 08/01/04 or later.
Transaction controls prevent the charging of certain expenditure types to a grant or contract which would typically not be an allowable direct charge.
Transaction controls are used as a way of improving University compliance with sponsor and federal requirements.

NOTE: Transaction control information is only distributed with the Notice of Award if a change has been made to the standard list of allowable expenditure types.  This change is usually effected by means of the CAS exception request which forms Part III of the Proposal Approval Sheet.   Transaction control templates may also be modified due to changes in sponsor rules, although this is a less common occurrence.

As of 08/01/04 there are three transaction control templates for three categories of award:

1. Federal Awards
   
   All new federal awards except for fellowships or training grants will be assigned the federal award template; this template will prevent the charging of the following expenditure types/items without the prior approval of OSP via Part 3 of the goldenrod proposal approval sheet:
   
   

Expenditure Category Continuous Charges Continuous Charges Continuous Charges Continuous Charges Continuous Charges Continuous Charges Contractual Services Contractual Services Contractual Services Contractual Services Contractual Services Contractual Services Contractual Services Contractual Services Contractual Services Contractual Services Contractual Services Contractual Services Contractual Services Contractual Services Contractual Services Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Equipment Faculty Salaries Faculty Salaries Faculty Salaries GTA/GRA GTA/GRA Plant and Improvement Plant and Improvement Property and Improvement Property and Improvement Scholarships & Fellowships Scholarships & Fellowships Scholarships & Fellowships Scholarships & Fellowships Scholarships & Fellowships Scholarships & Fellowships Scholarships & Fellowships Scholarships & Fellowships Scholarships & Fellowships Scholarships & Fellowships Scholarships & Fellowships Scholarships & Fellowships Scholarships & Fellowships Scholarships & Fellowships Scholarships & Fellowships Supplies & Materials Supplies & Materials Supplies & Materials Supplies & Materials Supplies & Materials Supplies & Materials Supplies & Materials Supplies & Materials Supplies & Materials Supplies & Materials Supplies & Materials

Expenditure Type Insurance, Boiler & Machinery Insurance, Bonds & Surety Insurance, General Liability Insurance, Malpractice Insurance, Property Insurance, Worker’s Comp Professional Licenses & Fees Svcs, Attorney Svcs, Auditing Svcs, Bottled Water Svcs, Catering Svcs, Clerical Svcs, Computer Software Maint Svcs, Fiscal Svcs, Laundry & Linen Svcs, Legal Svcs, Memberships to Orgs Svcs, Personnel Mgmt Svcs, Subscrip, Publications Svcs, Telecom, Cell, Internet Svcs, U.S. Postal Eq Capital Built-In Eq Capital Educational Eq Capital Household Eq Capital HSF Donated – UVA Own Eq Capital Library Eq Capital Mechanical Eq Capital Office Furniture Eq Capital Office Machines Eq Capital Recreational Eq Capital Voice & Data Eq NonCapital Built-In Eq NonCapital Desktop Comp Eq NonCapital Educational Eq NonCapital Household Eq NonCapital Law Enforcement Eq NonCapital Library Eq NonCapital Mechanical Eq NonCapital Mobile Comp Eq NonCapital Office Furniture Eq NonCapital Other Comp Eq Eq NonCapital Recreational Eq NonCapital Voice & Data Fixtures Library Books Office Appurtenances Salary, Faculty, Admin FT Salary, Faculty, Admin PT W/B Salary, Faculty, Admin PT WOB Wages, GTA, Non-Student Wages, GRA, Student Construction, Building Imp Construction, Building Site Improvements Site Preparation Fell, Assist, Conv, Grad Fell, Assist, In, Grad Fell, Assist, Out, Grad Fell, Other Fees, Grad Fell, Stipends, Intl, Grad Fell, Stipends, Non-Student Fell, Stipends, Post-Doc, Grad Fell, Stipends, US, Grad Schol, Assist, Conv, Undergrad Schol, Assist, In, Undergrad Schol, Assist, Out, Undergrad Schol, Stip, Intl, Undergrad Schol, Stipends, US, Undergrad Schol, Tuition, In, Undergrad Schol, Tuition, Out, Undergrad Supplies, Building R&M Supplies, Coal Supplies, Computer Operating Supplies, Custodial R&M Supplies, Educational Supplies, Food Svc Supplies, Laundry & Linen Supplies, Law Enforcement Supplies, Merchandise Resale Supplies, Office Supplies, Stationery & Forms




2. Subcontracts
   
   This transaction control template applies to all subcontracts issued to an outside entity.  The template restricts direct charges allowed on a subcontract to two types (up to the first $25,000):
   
   - Contractual Services, Svcs, Subcontracts, OSP No F&A
   - Contractual Services, Svcs, Subcontracts, Spon Pgm
   
   
3. Fellowships and Training Grants
   
   This transaction control template will be applied to all federal fellowships and training grants.  It will prevent the charging of expenditure types defined in 1. above as well as any faculty salaries without the prior approval of OSP via Part 3 of the goldenrod proposal approval sheet. 

OSP will assign transaction control templates to the award types described above at the time an award is made and set up in Oracle.  OSP will review proposal files for Part 3 of the goldenrod proposal approval sheet to determine whether an exceptional  circumstance exists for allowing the use of expenditure types, which would otherwise be unallowed by the transaction control template for the award.
If, for example, you are submitting a proposal for an award which will include research that involves conducting an extensive survey, you might submit a justification request for the use of postage as an allowable expenditure type, in order that the survey might be mailed out to participants.  Postage is generally considered an indirect charge, but in an exceptional circumstance in which there might be a more predominant use of such an expenditure type, an exception may well be granted in order to facilitate research in such a unique circumstance.  Other items which are, under cost accounting standards, typically considered as indirect costs, include, but are not limited to, the following:

Supplies/Equipment
Audio/Visual Equipment; Beepers; Books; Calendars; Cell Phone and related charges;
Clerical Salaries; Cloth Lab Coats; Color printer stylus; Fed Ex: applications, publications, etc.; General Copies; Hanging Folders/Manila Folders; Inkjet stylus; Instruction manual for software such as Excel; Internet Connections and Dial-up Costs; Lab Notebooks; Labels; Legal Pads;
Local Phone Charges; Memberships;Office Furniture; Overhead bulb; Palm Pilots; Paper for
copies, printers, etc.; Paperclips, binder clips; Pens, pencils, markers; PhotoShop; Office 2000; Adobe Acrobat; Corel Draw; Windows Upgrade; Pins; Postage; Poster Board; Post-it Notes; Service contract on copier; Sharpies; Stapler/Staples; Subscriptions (i.e., journals, magazines);
Toner Cartridges; Transparencies; Write/Read-Write CD’s; Zip Disks/Diskettes

Services
Moving crates and boxes: Putting up shelving; Replacing cold water line

Generally Unallowable Charges
Entertainment; Food/Alcohol; Picture Frames, Jefferson Cups (Gift-related items)
OSP will attach to the internal Notice of Award (NOA) a list of expenditure types which are not to be charged to the award per the transaction control template as listed above.  The list will indicate which particular expenditure types are specifically excluded or included in each case.  While the list above refers to particular items, the transaction control template use expenditure types and thus may not correspond directly to a particular item. 

PLEASE SEE OSP’s Cost Accounting Standards Guidelines for further details.

AFTER-THE-FACT EXCEPTION REQUESTS
There may be exceptional circumstances that have not been clearly or adequately documented on Part 3 of the goldenrod.  Should you need to request the allowability of a particular expenditure type otherwise identified in one of these transaction control templates, a supplemental CAS exceptions form  should be completed and submitted for processing and approval. (The supplemental CAS exceptions form is essentially a stand-alone version of Part 3 of the Goldenrod and is for use in these “after-the-fact” circumstances.)  This document may be submitted electronically or faxed (2-3096) to Stewart Craig (spc4bj@virginia.edu) or Peggy Candler (pc3s@virginia.edu) in OSP’s Grants and Contracts Office.

NOTE: Only OSP Pre-Award personnel have the authority to approve changes to a signed transaction control template.

Requests for changes will be reviewed and processed within 24 hours of receipt.

End of Activity