Effective: October 1, 2011
Latest Revision: 2011
Monthly Review and Certification of Sponsored Program
Project or Award Expenditures
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 the15th calender 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]
The RS is the University’s electronic reconciliation system and is the required method of reconciling Projects and Awards. The RS facilitates the timely on-line review of monthly transactions and balances and documents the review and approval of each Project-Award combination.
Procedure 1-3, “Requesting an Alternate Reconciliation Schedule”
The RS contains roles specific to the reconciliation process. These roles are assigned to department personnel who are responsible for the completion of the review and approval of expenditures, and ensuring that the work is completed in a timely manner. The roles are described below:
The department or unit fiscal person, listed as the Preparer in the Reconciliation System for the sponsored project, is responsible for reviewing each expenditure charged to the sponsored program, Project/Task/Award combination in the University's Reconciliation System, to ensure its accuracy, and to ensure that sufficient source documentation, in the form of paper, or data residing in the Reconciliation System or supporting systems, is available.
After reviewing expenditures, the Preparer or alternate approves and certifies the appropriateness of the charges by recording His/Her signature in the reconciliation system, 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 Approver’s attention for clarification or correction as well as being notated in the comments section of the reconciliation system. This role will be populated from the Integrated System fiscal contact role. Alternates may be assigned in the RS only.
Note: From time to time there is turnover in the Preparer role. To keep role data accurate in the Reconciliation System, fiscal contact data in the integrated system must be accurate; any changes to fiscal contact should be sent to firstname.lastname@example.org. The request should include the old fiscal contact name, the organization involved and as necessary the project numbers to be changed.
The Preparer is responsible for insuring all signatures are in place and recons completed within the approved 15 calendar day period to remain in compliance with the University requirement. If the PI assigned an alternate to be the on-line approver, the Preparer must print the certification sheet after the alternate has approved and have it signed by the PI by the 15th of each month.
The Fiscal examiner is responsible for examining and verifying the work of the preparer. This is an optional role in the RS system for sponsored program awards. This role is unique to the recon system and currently does not exist in the integrated system.
The Principal Investigator will review monthly expenditures for errors, accuracy of charges and unusual or unanticipated charges. The PI has the choice to be the approver in the RS system or to opt out and designate an alternate to be the on-line approver. If the PI chooses to opt out they are to insure that the individual assigned as their alternate is in a position to be knowledgeable about project expenditures. After reviewing expenditures, the PI or alternate approves and certifies the appropriateness of the charges by recording His/Her signature in the reconciliation system. This role will be populated from the Integrated System Project Principal Investigator field. Alternates may be assigned in the RS only.
If the PI has opted out and chosen to assign an alternate to be the approver, the alternate will approve the on-line review by recording his/her signature in the reconciliation system thus indicating to the investigator that they have reviewed and approve of the expenditures. The PI must then subsequently review and sign a paper copy of the monthly financial reports to verify his/her approval of the expenditures for documentation in the files. The alternate is not allowed to sign this paper copy.
The Fiscal Officer is the person responsible for verifying that expenditures for the assigned PA combinations have been reconciled within the specified time constraints and according to University Policies and Procedures.
Note: Unlike other GM projects and awards, in the case of sponsored programs, the Reconciliation 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.
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.
A monthly review of PTA expenditures is an essential component of project management to insure financial and accounting integrity. This review is done immediately following the month end closing and should be completed by the 15th calendar day of the month following, so June should be completed by July 15th, 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).
The Preparer should resolve as many accounting errors or other reconciling anomalies as possible. Any questions about the appropriateness of particular expenses should be brought to the immediate attention of the Approver for clarification and/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 error is identified and processed in accordance with Cost Transfer Procedures 8-20, 8-21 and 8-22). Preparers should take extra care to verify that the expenditure type charged is appropriate and accurately reflects the item or service that is identified in the supporting documentation. So for example, a beaker should be charged as a Lab Supply but a Sharpie pen should be charged as an Office Supply. The Preparer should:
1. For each PTA combination, gather and review supporting documentation for expenditure transactions
2. Log on to the Reconciliation System and review each expenditure transaction charged to a PTA combination to ensure accuracy
3. Determine that sufficient source documentation exists for the transaction
4. Verify there are no unusual or unanticipated charges
5. Flag issues and record comments, if appropriate
6. Update reconciling items, if appropriate
7. When review is complete, route to the next level
8. Follow up on any transacti9ons that remain outstanding for more than one accounting period.
9. Run appropriate Discoverer report to verify Human Subject expenditures as that data has been redacted out of RS
10. File supporting documentation in such a manner that allows the documents to be readily retrieved and presented when requested for audit review. These records must be maintained in accordance with the University record retention policy.
A department may require an interim review prior to the Approver certification. This is an optional step.
1. Examine the work of the Preparer (s)
2. Review issues and record comments, if appropriate
3. Update reconciling items, if appropriate
4. Complete review and route to next level or return to preparer (s) for rework
University policy requires that a separate individual (the Approver), who has authority and responsibility for the funds, certify that the review is complete and that the transactions are reasonable and necessary. The Approver should:
1. Review the work of the Preparers and/or Fiscal Examiners
2. Review issues and record comments, if appropriate
3. Updates reconciling items if appropriate
4. Certifies and approves expenditures or returns to Preparer for rework
NOTE: The PI’s certification of project expenditures is a key piece of the documentation supporting the allowability, allocability and reasonableness of project costs. By using this system or if opting out by signing the paper copy, the PI certifies to the best of his/her 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 Reconciliation System.
Projects that have no activity (meaning no transactions) during the current fiscal year are available for review, but do not require signatures in the RS.