Policy: VIII.C.1

Issued: January 15, 1988

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

Latest Revision: November 8, 2005


COMPLIANCE WITH SPONSOR REQUIREMENTS

1.0 Purpose

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

2.0 Policy [Top]

2.1 Overview

In accepting sponsored awards, grants, contracts, or clinical trials, 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.

2.2 Responsibility of Principal Investigator

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

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 all applicable University, state, and sponsor requirements.

Responsibilities of the principal investigator include:

2.3 Cost Transfers

A cost transfer is a transfer to a sponsored award of a charge previously recorded elsewhere. Examples:

Sponsored program charges are to be correctly applied to the appropriate project-award combination. Cost transfers must be made occasionally to correct errors in cost distribution. Because guidelines on sponsored program expenditures are restrictive, every effort should be made to promptly identify and correct such errors.

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

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.

See also Procedure 8-20, "Preparation of Cost Transfers Involving Sponsored Program Accounts"
See also Procedure 8-21, "Retroactive Cost Transfers for Expenditures"
See also Procedure 8-22, "Retroactive Labor Distribution Cost Transfers"

2.4 Individual Effort Certification Reports

Individual Effort Certification Reports represent the University's system for documenting time and effort contributed to sponsored programs, facilities and administrative (F&A) 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:

See also Procedure 8-31, “Effort Reporting”

3.0 Definitions [Top]

4.0 References [Top]

See also Policy VIII.C.1A, “Compliance with Federal Sponsor Requirements”

5.0 Approvals and Revisions [Top]

       Previous version in effect from 1/15/88 to 7/6/00 available in policy archive.
       Previous version in effect from 7/7/00 to 6/30/02 available in policy archive.

 

Maintained byUniversity Comptroller
© 2000 by the Rector and Visitors of the University of Virginia