Contracts and Grants Policy 5 – Responsibility for Sponsored Projects

Promptness

Upon acceptance of a sponsored project, the University is responsible for promptly pursuing the research, training or public service called for by the agreement.

Compliance with Agency, State and University Regulations

Project directors and principal investigators have primary responsibility for conducting the sponsored effort in accordance with award terms and conditions and within the funds allocated for such effort. They also are responsible for the programmatic direction of the research project and for initial authorization of all expenditures charged to the award budget. The principal investigator is ultimately responsible for expending funds in compliance with all agency, State, and University regulations.

Deans, directors, and department heads have a corollary responsibility for assuring that all sponsored programs conducted within their jurisdiction conform to the guidelines established by the Southern Association of Colleges and Schools and are consistent with agency, State and University policies and available funds.

The Office of Contracts and Grants is responsible for acting as a liaison between the project directors and principal investigators and the agency regarding fiscal matters. This includes financial reporting and financial compliance monitoring.

Financial Information and Financial Compliance Monitoring

The Office of Contracts and Grants has the primary responsibility to provide the principal investigator with financial information necessary to effectively manage a sponsored effort and to assure that all parties comply with the financial terms of the agreement. Refer to the Accounting and Budgets section of the Policies and Procedures Manual for further information on accounting policies and procedures.

It is the Principal Investigator’s responsibility to make prudent use of funds awarded for a sponsored project, to assure that expenditures are appropriate and directly relate to the budget and intent of the award, and comply with applicable University, State, Federal, and agency directives. (See Policy 8 – Expenditure Guidelines for additional information.)

The Office of Contracts and Grants monitors expenditures to insure compliance with applicable rules, regulations and directives. Many types of expenditures related to sponsored projects are handled in the same manner as expenditures for other fund sources and are subject to the same routine processing, reviews, approvals and other controls. However, some types of expenditures related to sponsored projects require a different level of scrutiny to assure fiscal compliance with the award. The Office of Contracts and Grants must approve them prior to processing (through the routine processing for other types of expenditures.) They include

  • Salaries and Wages
  • Contracted Services
  • Subcontracts & Sub-awards
  • Foreign Travel
  • Food
  • Scholarships

Following are the specific forms to be used, or references to the appropriate offices to be contacted, in order to request expenditures be made.

Salary Documents

  • For appropriate staff/SPA (Subject to the Personnel Act) employee documents, please contact Human Resources.
  • For appropriate faculty and administrative staff/EPA (Exempt from the Personnel Act) employee documents, please contact the Office of the Provost.
  • For appropriate regular student payroll documents, please contact the Payroll Office.
  • For appropriate work-study student payroll questions, please contact the Student Employment Office.
  • For appropriate graduate assistantship student documents, please contact the Graduate School.

Contracted Services

  • BANFIN-32 Expenditure Authorization – For use if you have an invoice.
  • BANCPS Contracted Services – For use if you have a contract, letter of agreement, or no invoice for a contracted service.

Honoraria

  • BANHON Honoraria – For use if you have a letter of understanding or no invoice.

Sub-awardees/Sub-contracts

  • CGBANFIN-32 Expenditure Authorization – For use if you have an invoice.

Travel

  • TRV-1  Travel Authorization/Expense Report – Calculated and Uncalculated Tabs located at the bottom

Food

  • BANFIN-32 Expenditure Authorization – For use if you have an invoice.

Scholarships for Students

  • For special forms and processing instructions for scholarships for students involving contracts or grants, please contact the Financial Aid Office.

Scholarships for Non-Students

  • BANFIN-32 Expenditure Authorization- For use if you have an award letter.

Non-reimbursement by Contract or Grant Agency

The financial responsibility for any non-reimbursement by the contracting or granting agency of expenditures made by the principal investigator rests with the department or school having primary responsibility for the project.

In the event of such non-reimbursement, the principal investigator, the department and college/school will be accountable for reimbursement to the University for these expenditures.

However, in some instances of non-reimbursement there are complexities beyond the control of the principal investigator. When such instances occur, an exception may be made based upon the merits of the specific situation, but reimbursement must be provided by the department and college/school.

Recurring problems with a sponsoring agency or other symptomatic issues regarding non-reimbursement will be reviewed by UNCG official(s) responsible for sponsored projects administration, who will take appropriate measures to address any significant problems.

Questions or Problems Concerning Financial Aspects of Projects

The Office of Contracts and Grants is available to assist with questions or problems encountered by the principal investigator in connection with any phase of the financial management of his or her project. We highly encourage that the principal investigator contact the Office of Contracts and Grants about an actual or potential financial problem prior to contacting a sponsoring agency. The primary contact person for your department can be located by reference to the chart in Introduction 5.

Delegations of Authority to UNCG

In accordance with federal Office of Management and Budget Circulars, revisions of program plans and budgets are required to be approved by the federal funding agency. Following are the examples of situations requiring approval by the funding agency.

  • Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval).
  • Change in a key person specified in the application or award document.
  • The absence for more than three months or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
  • The need for additional Federal funding.
  • The transfer of amounts budgeted for indirect costs to absorb increases in direct costs, or vice versa.
  • The inclusion of costs that normally require agency prior approval.
  • The transfer of funds allotted for training allowances (direct payment to trainees) to other categories of expense.
  • Unless described in the application and funded in the approved awards, the subaward, transfer or contracting out of any work under an award.

Regulatory requirements can vary contingent on the federal sponsor, or federal program. In some instances for some agencies, UNCG has been granted authority to revise program plans and budgets. However, there is inconsistency among the federal agencies and programs as to what requires agency approval versus the authority delegated to UNCG. Accordingly, the Office of Contracts and Grants should be consulted to determine if Institutional or Agency approval is required. In either case, proper documentation is needed for audit review. Specific information will need to be provided by the researcher via email or through written correspondence to the Office of Contracts and Grants. By answering the following questions, usually the needed fiscal information will be provided:

  • Why funds are being redirected?
  • Why funds will not be needed as originally planned?
  • And, in cases where the funds are normally considered administrative/overhead type costs, what is the direct research-related purpose of the item(s) under consideration?

Closeout of Agreements

In order to comply with federal regulations addressing project closeout (Federal Circulars A-21 and A-110), a formal project closeout process was established. This process consists of the following steps:

  • The Office of Contracts and Grants, in order to lay out the actions to be taken, will contact the principal investigator within 60 days prior to the end of the project.
  • The principal investigator is responsible for initiating any requests for extensions by the funding agency via the Office of Sponsored Programs. Prior to requesting the extension, an assessment of the budget status and the timeframe in which to complete the expenditures should be addressed with the Office of Contracts and Grants. This will help assure that all fiscal matters, including matching, are appropriately considered in the request for extension.
  • Accounts will be frozen after the project termination date so that transactions after that time can only be charged to the account after review and approval of the Office of Contracts and Grants.
  • The principal investigator will work with the Office of Contracts and Grants to ensure that all transactions are completed and charged to the accounts within the prescribed sponsor deadline. At most this could be a 90-day period following the end of the grant.