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Compliance
With Sponsor Requirements
The principal investigator is responsible, on behalf of the University,
for sound technical, fiscal, and administrative management of a
project or program in accordance with both University and sponsor
requirements. All sponsored program charges should be correctly
applied to the appropriate ledger five account. Cost transfers among
accounts may be approved for certain reasons but they must be justified
in writing and may not be more than 120 days old. Individual Effort
Certification Reports must be completed to document time and effort
contributed to sponsored programs, indirect cost activity, and major
functions.
See
also:
Records
Retention and Disposition
Records Retention: General
Requirements
Preparation
of Interdepartmental Transfer Invoices (IDT's)
Preparation of Cost Transfers
Involving Sponsored Program Accounts (Ledger 5)
Preparation of Individual
Effort Certification Report
Compliance
With Sponsor Requirements
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Preliminary
Account Request
In order not to interrupt on-going research or delay the start of
new projects, the principal investigator may request that a preliminary
account be set up for up to three months when a new or continuation
award is assured. Should the expected support fall through, the
originating department is responsible for expenditures incurred.
See
also: Preparation
of Preliminary Account Request Form
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Consistent
Treatment of Sponsored Program Costs
Federal regulations require that costs be treated consistently in
both federally and non-federally funded programs. Costs incurred
for the same purpose in like circumstances must be considered either
direct costs or Facilitities & Administrativecosts (i.e., F&A
or "indirect costs") in all University activities. Direct
costs are those identified specifically with a particular project
such as salaries of faculty and research associates, equipment and
travel. Normal F&A costs are those not identified specifically
with a particular activity such as administrative and clerical salaries.
F&A costs may be charged directly to non-federal awards, if
permitted by sponsor policies or otherwise approved by the sponsor,
and to federal awards if circumstances related to the program are
clearly different from normal operations of the institution.
See
also:
Budgeting
the Direct Costs of Sponsored Projects
Consistent
Treatment of Sponsored Program Costs
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Budgeting
Direct Costs of Sponsored Programs
Direct costs are those costs which can be identified specifically
with a particular sponsored program project and which can be practically
assigned (charged) to the University account established for the
purpose of accumulating program costs. Indirect costs are those
not attributable to a particular program and are recovered through
the application of a fixed indirect cost rates. The University Object
Code attached to each cost category is to be used in preparing a
sponsorded program proposal budget. Some categories such as faculty
salaries and associated fringe benefits (rates vary by employment
title), and equipment routinely are considered direct costs. Other
costs such as consultative services require justification for inclusion
as a direct cost and some costs can be a direct cost only on specific
types of programs, such as trainee stipends on a training program.
See
also: Budgeting
the Direct Costs of Sponsored Projects
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Indirect
Costs
The total cost of a sponsored program consists of direct costs and
indirect costs. Direct costs are readily identified with a particular
project (such as research faculty salary) and indirect costs are
those costs incurred in support of many activities, the portion
of which pertaining to the project is difficult to determine (such
as secretarial assistance). The allocation of a portion of all such
indirect costs to particular projects and activities is accomplished
by applying an indirect cost rate to the modified total direct costs
(MTDC) of the project. The MTDC equals total direct cost less categories
(such as equipment) for which no indirect cost is charged. This
rate varies according to type and place of the activity. Of the
total indirect cost charged, 30% goes to the state administration
and 70% is further distributed by the University (20% for state-approved
research and 50% to the dean, department and other entities). Greater
specificity and examples of direct and indirect costs (including
permissible exceptions) reflecting 1997 federal guidelines are given
in Document 8.C of this Research Guide.
See
also: Indirect
Costs
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Determination
of On-Grounds/Off-Grounds Status
Sponsored research will be classified as taking place "off-Grounds"
if the research takes place (or predominantly takes place) in a
facility not owned by the University and the "off-Grounds indirect
cost rate applies. If the work has been approximately evenly divided
between "on-Grounds" and "off-Grounds," then
the program will use both rates in the same proportion. Requests
for approval to use "off-Grounds" indirect cost rates
must be made in writing to the University Comptroller.
See
also: Determination
of On-Grounds/Off-Grounds
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Application
of Indirect Cost Rates
The general policy of the State of Virginia and the University is
to recover full indirect costs (termed F & A Costs, as of July
1997) by applying approved indirect costs rates (see Research Guide-8.E)
to all sponsored programs. Exceptions can be made if the sponsor
has limitations on indirect cost recoveries or if the project satisfies
certain approved criteria which make application of the usual rate
unjustified. Requests for exceptions must be made in writing.
See
also: Application
of Indirect Cost Rates
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Administrative
and Clerical Salaries
The University of Virginia subscribes to the policy and guidelines
of the Office of Management and Budget (OMB) that administrative
and clerical staff salaries should normally be treated as indirect
costs. Exceptions when these costs are clearly attributable to a
particular program are allowed if justified in writing and approved.
Examples include large, complex programs and aprograms involving
extensive data manipulation or making travel or meeting plans for
large numbers of persons.
See
also: Charging
Administrative and Clerical Salaries
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Sponsored
Program Deficit Accounts
Sponsored programs accounts (ledger 5) allow expenditures, according
to approved budget categories, before collection of cash. The Office
of Sponsored Programs (OSP) collects payment on actual expenditures,
up to the limit of the budget. Once a deficit occurs, no further
expenditures will be paid until corrective action has been taken.
Because overcharges cannot be billed to the sponsor, the principal
investigator must ensure the account does not exceed budget. Any
account deficit must be corrected before OSP will process additional
charges and if it is not corrected within 90 days, the deficit will
be transferred to the departmental overhead account.
See
also: Sponsored
Program Deficit Accounts
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