Systems and Procedures

A Part of Finance

Policies and Procedures | Contracts & Grants

Introduction Statements

General
The University encourages the involvement of University personnel in seeking both federal and non-federal funds for sponsored research, training, and public service projects. These projects provide an opportunity for the faculty to extend themselves beyond the classroom and gain experience that can be utilized in their teaching and writing. This policy is consistent with the University’s goal to seek opportunities consistent with the University’s teaching, creative expression, and research standards; to serve the people of the state; and to promote understanding of the resulting mutual benefits.

Policies related to externally funded grants and contracts must ensure conformity of this activity to the stated purposes of the institution, provide an appropriate balance between this type of activity and instruction and guarantee institutional control of the administration of research projects. The researcher’s freedom to investigate and report results must be preserved. Research support from outside agencies should not undermine these basic research principles.

The institution must establish a clear policy concerning a faculty member’s division of obligations between research and other academic activities. The institution must ensure that this policy is published in such documents as the faculty handbook and made known to all faculty members. The institution should develop policies regarding summer salaries paid from contracts and grant funds, salary supplements paid from grants during the regular academic year and fees for consultative services undertaken by faculty members. These policies must also be published and made known to the faculty.

In accepting funds from outside agencies, the institution must take steps to ensure that the institution maintains control of research and instruction. Because many agencies attach stringent regulations directing and limiting the activities for which they provide funding, the institution must safeguard its prerogative to control its own activities.

Continuity of support for general institutional activities must not be endangered by acquisition of research contracts and grants. Grants are given and contracts are made for limited lengths of time. When the institution become dependent, even partially, upon such funds for faculty salaries and/or graduate fellowship and assistantship stipends, termination of grants and contracts can jeopardize an entire educational program. It is also important that the institution not become dependent upon indirect cost allowances from grants and contracts to support its regular operating budget.


Description of Offices Involved
To assist the faculty with submitting proposals and post award administration of contracts and grants, the University has established two offices: the Office of Sponsored Programs and the Office of Contracts and Grants.


Office of Sponsored Programs
The Office of Sponsored Programs (OSP), a department within the Provost’s Division, is available to help faculty and staff in the preparation and submission of research proposals. Subsequently, if funded, this office is involved in the programmatic aspects of administering the contract or grant. Accordingly, this office maintains all permanent files pertaining to the funded projects. Included in these files are the proposal, award letter, other communication with the awarding agency, and the final program report prepared by the principal investigator.

In addition, all the ancillary support activities needed for research (Animal Care Committee, Human Subjects Committee and other safety-related committees and responsibility for the internally funded programs) are housed in the Office of Research and Public/Private Sector Partnerships.

OSP is responsible for identifying potential funding sources and communicating such information to the faculty, maintaining contacts with potential sponsors and arranging appointments with such sponsors as requested by the faculty, and helping with the development of preliminary proposals to potential sponsors. In addition, the office is responsible for proposal processing–ensuring, prior to submission, that proposals conform to all agency requirements, that the proposed financial arrangements have been approved by the Office of Contracts and Grants and that special commitments have had prior internal review. This office is also the keystone for contract and grant administration, functioning as the liaison between the funding agency, the faculty member, and other University offices.

The Office of Sponsored Programs is the primary support organization for pre-award activity for sponsored programs at the University of North Carolina at Greensboro. As such, it works with the Office of the Provost for academic matters dealing with sponsored programs and with the appropriate financial officers on fiscal matters. All contract and grants represent obligations of the University and, as such, must be signed on behalf of the University by the Director or Associate Director of the Office of Sponsored Programs.


Office of Contracts and Grants
The Office of Contracts and Grants, a department within the division of Business Affairs, provides assistance with the fiscal matters dealing with project administration. This includes providing budgetary advice during proposal preparation, as well as, the financial management of the funds awarded to the University to insure compliance with direct and indirect costing directives of the sponsoring agency. Permanent files maintained by the Office of Contracts and Grants are: interim and final financial statements filed with the agency; copies of the original budget and any budget revisions; prior approval notices from the agency where applicable; and any other correspondence relative to the fiscal management of the grant.

This office publishes procedures to ensure that expenditures are made within the regulations and policies of the University, the State of North Carolina, and the Federal Government. In addition, the office advises principal investigators of any special regulations which may be imposed by the granting agency.


Organization of Manual
This manual includes the basic information needed by the principal investigator to manage a contract or grant within the guidelines established by the University and the sponsoring agency. Programmatic questions should be directed to the Office of Sponsored Programs and financial questions to the Office of Contracts and Grants.

General
The appropriate processing of funds from external sources is essential to guarantee that the intentions of the funding source are properly observed.


Description of Offices Involved
The Office of Sponsored Programs and the Office of Contracts and Grants have primary administrative responsibility over activities that will result in or that concern the development and subsequent administration of contracts, grants, or other agreements for external funding of University sponsored research activities. When funds are received in support of a sponsored research activity, there should be either a proposal which has been processed through the Office of Sponsored Programs (OSP), a research grant/contract that OSP has reviewed and signed off on, or some arrangement relating to the receipt of research funds which has been agreed to by OSP.

The Development Office has the primary administrative responsibility over activities that will result in or that concern fund-raising and gifts.

Questions regarding the classification of external funding should be directed to the Controller’s Office.


Definitions

Contract
An agreement to acquire, purchase, lease, or barter property or services that primarily benefit the sponsor. For an award to be considered a contract, it normally must contain all of the following elements:

  • Detailed financial and legal requirements must be included in a specific statement of work to be performed.
  • A specific set of deliverables and/or reports to the sponsor is required.
  • Separate accounting procedures are required.
  • Legally binding contract clauses must be included.

Grant
An agreement to transfer to the grantee money, property, services, or anything of value to accomplish a public purpose, such as support or assistance in an area of interest to the sponsor. For an award to be considered a grant, it normally will contain the following elements:

  • The statement of work must be phrased in general terms to allow the project director a significant amount of freedom to change emphases within the general area of work as the project progresses.
  • Deliverables are minimal, usually consisting of reports only.
  • Separate accounting procedures are required.

Gift
A donation of money, property, or anything of value to the recipient for the recipient’s ownership and use. Gifts normally contain only the following elements:

  • If there are any restrictions on use, they are limited to the University, a unit, a program, or an activity.
  • The amount of a gift may or may not bear any relation to the total cost of the program or activity.
  • There are no deliverables and/or reporting requirements.
  • Funds may be commingled with funds from other sources within the same accounts.

Purpose
The primary function of the Office of Contracts and Grants is to coordinate the administration and financial management of all contracts and grants awarded to the University. This includes providing the principal investigator with technical guidance on the budget during proposal preparation; reviewing and approving the fiscal portions of proposed contracts or grants prior to submission; establishing the required records for new grants and contracts; negotiating the award terms and amounts; and serving in an advisory capacity to a principal investigator within the fiscal framework of each individual project. It also includes: monitoring expenditure requests for applicability and appropriateness of charge as they relate to federal and state guidelines; monitoring the accounting for funds; preparing the fiscal reports; and maintaining the permanent fiscal files.

Services provided by the Office of Contracts and Grants (See Introduction 5 for a summary of services broken into pre-award and post-award) as delineated in this section do not relieve the principal investigator of his/her responsibilities concerning the financial aspects of a contract or grant.


Policy Priority
When the State or University has established a policy in an area not addressed by the sponsoring agency or when the established policy is more restrictive than the agency policy, the State’s or University’s policy governs.


Assistance
The Office of Contracts and Grants should be contacted for clarification of policies and procedures.


Location
The Office of Contracts and Grants is a department within the division of Business Affairs of the University and is the administrative responsibility of the Associate Vice Chancellor for Finance. The office is located on the second floor of the Moore Humanities and Research Building, Room 2511.

Policies

General
The basic guidelines for the administration of grants and contracts within the University of North Carolina are set forth in The University of North Carolina Policy Manual, Chapter 500.4 {R}, Regulations on Administering Sponsored Programs. The University of North Carolina Policy Manual, Chapter 500.4 {R}, Regulations on Administering Sponsored Programs states “All sponsored programs which are carried out by constituent institutions or other agencies of the University or on University-controlled premises or under the direction of faculty or staff members of constituent institutions or other agencies of the University, shall be subject to review and approval with respect to funding arrangements by the President of the University of North Carolina or by the Chancellor or other persons who have been specifically designated by the President. All formal applications to donors and sponsors for support of sponsored programs shall be submitted to donors and sponsors through the President and reviewed under such instructions and guidelines as the President may deem necessary.”

In actual practice, “Applications for grants and contracts may be submitted by the Chancellor or her designated representative as approved in advance by the President directly to a funding authority, without prior approval by the President, with the following exceptions:

  • Those under which the University assumes an express or implied responsibility to continue the program or activity beyond the life of the grant or to retain personnel initially employed under the grant or contract.
  • Those involving the creation of a new organizational unit (a department, center, institute, school, etc.) within the University or a constituent institution.
  • Those involving the planning or establishment of a new degree program or program track.
  • Those requiring matching funds or contributions that cannot be provided from current institutional resource levels.

Initiation of Proposals
Contracts or grants are normally awarded only after submission of a proposal to a funding source. The proposal describes a task to be performed or a project to be undertaken by the University or an agent of the University. It includes a budget statement clearly defining the total costs of the proposed project and the amount of funds requested from the funding source or agency. Proposals are prepared by the person who directs or is responsible for the proposed project within the University. This person is referred to as the principal investigator. Before beginning the proposal writing process, a principal investigator should contact the Office of Sponsored Programs to obtain access to RAMSeS, and review the guidelines for proposal preparation at the University of North Carolina at Greensboro. A potential principal investigator should check with the appropriate Department Head or Dean to determine the appropriateness of the project or program to be proposed before the proposal writing process begins.


Office of Sponsored Programs (OSP)
The University of North Carolina Policy Manual, Chapter 500.4 {R}, Regulations on Administering Sponsored Programs requires that certain procedures be followed throughout the University of North Carolina and specifies a standard internal processing form for all 16 campuses. The Office of Sponsored Programs is charged with administering the proposal submission procedures outlined in that Memorandum and refined regularly by General Administration. All proposals are to be processed through the Office of Sponsored Programs. OSP reviews each proposal to see that the proposed activity is in line with the programmatic goals of the University. In addition, the proposal is also reviewed for compliance with guidelines established by the funding source to which the proposal is to be submitted and with the appropriate University and State guidelines.


Preliminary Discussions with Funding Sources
Preliminary discussions of program objectives or project scope with a potential funding source are not discouraged. Pre-proposals need not be processed formally through the University. Unauthorized commitments must not be made by pre-proposals or informal communication of any kind. Valid commitments of grant or contract supported projects or programs can be made only through the established proposal submission process.


Office of Contracts and Grants
The Office of Contracts and Grants is responsible for the fiscal review of proposed projects and programs being treated as a contract or grant. You are encouraged to seek guidance early in the budget proposal development process. Your needs can be as varied as discussing methodology on how to develop a budget, reviewing the draft budget and budget narrative, to the final review of your budget and budget narrative. However, as all proposals are routed by the Office of Sponsored Programs to the Office of Contracts and Grants for budget approval as an automatic step in the proposal processing procedure, it is important to discuss your budget with us. Last minute requests for budget proposal review and approval may not be possible. Thus, please plan ahead and allow us the opportunity to help meet your specific budget proposal needs.

General Information
Since a properly prepared proposal has a better chance of obtaining funding than one that is not prepared properly, the principal investigator should allocate sufficient time for planning, coordination, and preparation of a proposal. Accordingly, the potential principal investigator should take advantage of the experience of colleagues and members of the faculty and staff who have knowledge that can be useful in program or project design and in proposal preparation. As a proposal is being formulated, a potential principal investigator should consult with the Office of Contracts and Grants, the Office of Sponsored Programs, and any other such offices as may be appropriate for a specific proposed project (e.g., Office of Human Resource Services, Purchasing Office, Instructional and Research Computing, and Statistical Consulting Center).


Basic Proposal Preparation
Proposals should be prepared according to the requirements or specifications of the potential sponsor and within any format that the sponsor may stipulate. In the absence of specific format or content specifications, the principal investigator should seek assistance from the Office of Sponsored Programs.

The preparer should be aware that, if a proposal is funded, the disbursement of funds is subject to regulations established by the University, by General Administration, and by the State of North Carolina as well as those established by the funding source. The Office of Contracts and Grants can offer assistance in budget preparation and should be contacted while the proposal is still in draft form. It is very important that a proposed budget be constructed to fully and accurately reflect the level of support needed to successfully complete a proposed project. Refer to Procedure No. 2 for assistance with proposal preparation and Procedure No. 3 for budget preparation.

Some budgetary matters are particularly critical to proposal preparation and the potential principal investigator must be aware of these matters and must integrate them into the proposal preparation process from the beginning. Two very critical factors are:


Cost Sharing and Matching
The specific conditions for cost sharing and matching required by a sponsoring agency must be carefully identified and evaluated. All cost sharing and matching requirements must be discussed with the appropriate Department Head and/or Dean in the early stages of proposal preparation. Cost Share commitments must be included in the Cost Sharing or Cash Matching section of the proposal budget tab in RAMSeS. For detailed information on cost sharing and matching, refer to Policy No. 9 and Procedure No. 12.


Facilities and Administrative Costs
Facilities and administrative (F & A) costs, which used to be referred to as indirect costs, represent a substantial outlay on the part of the University and the State. Recovery of facilities and administrative costs is essential, and the rate of facilities and administrative costs charged is determined by formal negotiations with the Federal government. Please refer to Facilities and Administrative Guidelines for the current rate. Established facilities and administrative cost rates must be included in every proposal unless an alternative rate or exemption has been clearly established through existing policy or practice. Requests to use less than the established rates in other instances must be approved in advance by the appropriate Department Head and Dean before forwarding the request to the Director of Contracts and Grants for the approval of the Vice Chancellor for Business Affairs. This is based upon the recommendation of the Provost.

The Research Administration Management System and electronic Submission, or RAMSeS is the official online proposal routing, submission, tracking and award management system used by The University of North Carolina General Administration. Used by nearly all the schools in the UNC system, this system is used to create and manage all sponsored projects for the University. What was once a paper-based process, which involved acquiring written signatures from authorized University officials, now is an entirely electronic process in which proposals can be routed across the University and thereby proposals can be reviewed and authorized anywhere that has an internet connection. This allows both researchers and research administrators to manage research more efficiently and effectively than was possible before. RAMSeS integrates both departmental research administration and The Office of Sponsored Programs with The Office of Contracts and Grants, The Office of Research Compliance, The Office of Innovation Commercialization, and Community Engagement, to allow a greater amount of collaboration as each proposal is processed and each award is received. – See more at: RAMSeS Login.

General
Project implementation begins either with the University’s formal acceptance of an award, or an Assumption of Risk request, which is approved by the Associate Provost of Research. Please refer to the Office of Sponsored Programs web page for information regarding Assumption of Risk.


Agency-University Relationships
Awards are made to the University either directly or through an agent of the University.


Formal Acceptance of Awards
Awards are to be accepted only by the Chancellor or by those to whom he/she has delegated signatory authority. No other individuals are authorized to commit or otherwise bind the University unless specifically delegated to do so by the Chancellor.


Negotiations
In some cases, before an award is made to the University, it is necessary to negotiate final contract or grant terms (e.g., scope of work, understandings on proposed expenditures, billing and financial provisions, or contract and grant amounts). Negotiations of this nature must be coordinated with the Office of Contracts and Grants and the Office of Sponsored Programs and may require reprocessing through Department Heads, Deans and Directors, and the appropriate Vice Chancellors.

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 (.xlsx) Expenditure Authorization – For use if you have an invoice.
  • BANCPS (.pdf) Contracted Services – For use if you have a contract, letter of agreement, or no invoice for a contracted service.

Honoraria

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

Sub-awardees/Sub-contracts


Travel

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

Food


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


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.

General
For most grants and contracts, the date to begin the funded research and/or other activities is subsequent to the receipt of the official notification of award from the sponsor. The official notification is in the form of electronic notification or a mailed or faxed officially signed document.

Upon receipt of a formal notice of award, the Office of Contracts and Grants takes the following steps:

  • Assigns a Contract or Grant Fund Number.
  • Establishes the parameters for the fund.
  • Establishes the line item budget that is congruent with the University’s Chart of Accounts.

The principal investigator is notified via e-mail of the fund number and other pertinent information on a Grant Award Brief form (Appendix 8.) The Grant Award Brief provides award information in a synopsized format, requested information and a line-item breakdown of the approved budget. The Grant Award Brief with the attached line-item budget breakdown serves as a ready reference to outline significant requirements and designates the responsible UNCG Contracts and Grants Specialist.

Note: The principal investigator does not have authority to expend on a sponsored project until the Grant Award Brief is issued. See Appendix No. 8 for a sample of a Grant Award Brief. Refer to Policy No. 8 for expenditure guidelines. No charges can be made against existing funds that are not permanent charges. More specifically, charges may not be transferred later as a mechanism for starting the grant in advance.

Furthermore, Pre-Award Costs cannot be incurred in advance of the effective date of the award unless the exception is specifically recognized, defined, and authorized by the award agreement or via an Assumption of Risk request.


Assumption Of Risk Policy
Please refer to the Office of Sponsored Programs web page for handling situations where the official notice of award has not been received.

University Channels to be Followed on Administrative Matters
Communications between the University and the sponsoring agencies relative to financial management of projects are to be coordinated through the Director of Contracts and Grants. This includes, but is not limited to, negotiation of project terms or amounts, budget revisions, interpretation of contract/grant language or any events which may require formal approval of the University or sponsor. To facilitate the identification of written correspondence with the applicable award, reference must be made to the UNCG fund number assigned to the contract or grant.


Leaves of Absence
When a principal investigator (P.I.) is scheduled for a leave of absence, it is essential that written concurrence be obtained from the sponsor(s) involved prior to departure on the leave of absence. Satisfactory arrangements must be made for a substitute P.I. and continuation of the specified research or training. The definition of a leave of absence varies from sponsor to sponsor. For example, the National Science Foundation and NIH consider an absence in excess of three months to require advance agency approval. Other sponsors are more restrictive and reserve the right to approve any change in key project personnel. Adherence to sponsor requirements for advance notification and clearance minimizes the chance of problems with and possible costs disallowances by a sponsor. Coordination should be made through the Director of Contracts and Grants who can offer any assistance that may be required.

Should a P.I. plan to transfer to another university or terminate UNCG employment for other reasons, the appropriate Contract Specialist(s) should be contacted relative to sponsor requirements applicable to transfer or termination of an award. For example, the National Institutes of Health (NIH) requires the submission of “Official Statement Relinquishing Interests and Rights in a Public Health Service Research Grant” when the P.I. plans to continue the research at another institution. If the P.I. plans to request the transfer of equipment, Policy No. 11: Equipment Management, should be consulted.

Technical communications between P.I.s and their counterparts in the sponsoring agencies are authorized and encouraged, but direct communication between P.I.s and sponsor agency program directors on matters possibly affecting contractual agreements is to be avoided. Assistance in such matters is readily available from the Office of Contracts and Grants.

It is extremely helpful to Contracts and Grants if the assignment control number (e.g. via PHS Form 3830) given a proposal by the sponsor, primarily PHS, is provided our office. It facilitates inquiries to the sponsor. In those cases where a proposal is deferred, rejected, or not funded it is also helpful to forward a copy of such information to the Office of Sponsored Programs.

General
Most federal and non-federal sponsoring agencies or organizations issue their own policy guidelines and directives defining acceptable costs for purposes of their program(s). Despite a great deal of commonality as to content, there are sufficient variations in policies to make it impractical to issue and maintain a policy compendium. Individual agency or organizational directives must be consulted for authoritative guidance.

The purpose of this section is not to repeat definitions of costs elements, but rather to provide clarification, guidance, or references as to University policy. Additionally, special considerations or problems will be highlighted.

To facilitate reference, arrangement of this section is alphabetical. For guidance on items not referenced, please consult sponsor policies or contact the Office of Contracts and Grants. For comments and guidance on facilities and administrative (indirect) costs, please consult Policy No. 15.


Alcoholic Beverages
Costs of alcoholic beverages are unallowable.


Alterations and Renovations
Such costs are allowed only in exceptional cases and are subject to specific sponsor guidelines and limitations. Alterations and renovations are normally authorized only for specialized facility requirements and not for general purpose space such as administrative offices.


Books and Periodicals
Customarily such items are allowable as a direct cost when required for the conduct of a project. However one major federal sponsor, Public Health Service (PHS), is concerned with the project need for such items where library service is available. As PHS requirements and perspectives tend to influence federal audit requirements, it is recommended that requisitions for books or periodicals to be charged against federal projects be accompanied by a brief explanation on the requisition as to why it is not feasible to obtain them through normal library service. A brief justification on the requisition will likely preclude questions of relevancy and necessity during any audit review.


Consultant Services
Proposed consultant charges are subject to particular scrutiny by a sponsor. The federal government permits such charges if budgeted in advance and if it can be documented that such services are essential and will be obtained from the most qualified person at reasonable and normal rates.

All consulting services are to be obtained in concurrence with established University policy. Some of the established and more significant policy elements are as follows:

  • Full-time University and other State employees are not authorized to be paid consultant fees by the University. This restriction also applies to corporations and partnerships in which an employee of the University or faculty member serves as either a principal or employee.
  • Payments to former University employees for consultant services will be closely scrutinized and may require additional documentation to verify status as an independent contractor.

Intra-University Consultation
Intra-University consulting (consulting across department lines) is intended to meet those needs where project participation by certain University faculty members is nominal and it is contemplated that the faculty member will participate in the project from his/her “free” or “uncommitted” time. The term “free” or “uncommitted” time as used herein refers to time over and beyond that required to fulfill basic faculty responsibilities. The term extramural effort is also frequently applied to describe work done during this time. Effort of this nature should not be disproportionate or unreasonable in light of the faculty member’s other research and instructional commitments.

Intra-University consulting must be approved in advance by the sponsoring agency. Normally, identification of the faculty members by name in the proposal narrative and budget is sufficient.

To preclude any confusion of intra-University consultation payments with the normal personnel activity report certification process (the major goal is to sustain the propriety of professional salary charges to awards), requests for payment should, consistent with fact, certify that the effort was from “free” or “uncommitted” time of a faculty member.


Consultant Travel
University policy permits both professional fees and travel expenses to be combined in one payment to consultants. This is the preferred method of handling such payments, providing the sponsor agency permits the processing of such payments in this manner and providing that the travel allowance and associated allowances can be reasonably estimated. When consultants are to receive travel reimbursements that are to be exempt from 1099 reporting requirements, the award budget should include such travel expenditures under the travel account code and be supported with original receipts.


Contingency Funds or Reserves
Separate budgetary cushions or allowances for unexpected expenditures are not allowable cost elements to federal agencies. This does not preclude the utilization of reasonable escalation factors applied to cost elements such as salaries and wages or supplies when preparing the budget.


Dual Employment
When a principal investigator utilizes personnel at other state agencies, payment cannot be made directly to the person employed. Form CP-30, Dual Employment, must be completed and remitted to the appropriate agency. For further information and instructions, refer to Policy No. 4 Budgeting – Dual Employment of the Financial Planning & Budgets section of the Policies and Procedures Manual.


Encumbrances Near To and After Termination Date
Orders for supplies and equipment must be placed sixty to ninety (60-90) days prior to the account expiration date to ensure delivery and utilization. Items not received and/or utilized during the award period are routinely disallowed on an audit.

If additional time is needed to complete the research project, the principal investigator must contact the Office of Contracts and Grants for aid in securing fiscal information before submitting an official request for a no-cost date extension to the sponsor via the Office of Sponsored Programs. Otherwise, the University must automatically cancel outstanding encumbrances thirty to sixty (30-60) days after termination to avoid disallowances on an audit.


Entertainment
Costs of amusements, social activities, entertainment, and incidental costs related thereto are not allowed.


Equipment
Purchases of specialized equipment are normally allowable with advance approval from the sponsoring agency. Purchases of general office equipment and furnishings, such as desks, chairs, tables, etc., will generally not be approved by a federal agency.

Whenever practical, equipment already in possession of the University will be utilized to meet research needs. Project funds are normally used to pay for only authorized equipment acquired sufficiently in advance of the ending date (prior to last 90 days) of the project period to be effectively used on that project. Purchases of equipment not meeting the effective utilization test, particularly if there is not a follow-on or continuation award, are usually questioned by auditors and generally result in a cost disallowance or exception.


Honoraria
An honorarium payment is characterized by the primary intent to confer distinction upon an individual. Payments of this nature are not allowable charges to sponsored research. The term honoraria must not be used in reference to the procurement of consultant services.


Pre-Award Cost
Incurrence of project costs prior to the effective date of an award must be avoided. Research or training effort should not be initiated prior to the effective date of an award with expectation that such costs will be allowed. Such charges will be permitted only in exceptional cases and must be approved in advance. Please refer to the assumption of risk policy information online.


Retroactive Cost Transfers
The federal guidelines for cost transfers state, “any cost allowable to a particular research agreement may not be shifted to other research agreements in order to meet deficiencies caused by overruns, to avoid restrictions, or for other reasons of convenience.” As a result, the Office of Contracts and Grants must screen all requests for transfer of expenditures to ensure compliance with these regulations. Federal regulations normally allow such transfers only within ninety (90) days of the original encumbrance.

When applying for a retroactive costs transfer, send a memo to the Director of Contracts and Grants requesting the transfer. The memo must contain all details pertaining to the transfer and a copy of the document showing the expenditure. In addition, a full explanation and reason for the transfer should be given.


Salaries and Wages
Salaries and wages are allowable as a direct cost to the extent that they are reasonable and conform to the established University salary and wage policy. All personnel involved in a sponsored project’s effort, whether faculty, professional staff, clerical staff, or students (research assistants), must be paid in accordance with University and State guidelines. The salary and wage categories and job or position classifications on sponsored projects must be congruent with those established for all other employees of the University. Salary rates and increments are therefore subject to the regulations applied to all other University employees of the same classification. Exceptions only result in audit disallowances.

Salary and wage rates contained in a proposal, including projected increases, are budgetary figures. All personnel commitments are handled in conformity with established University salary and wage policies. Budgetary data contained in a proposal does not in any way supersede such policies.

All University personnel must be paid through the University payroll system, even if they are considered consultants. In addition, all students that are enrolled at the University and are being paid for services rendered must be paid through the University payroll system. Refer to Policy No. 9 Payroll – University Payrolls of the Financial Services section of the Policies and Procedures Manual for additional payroll instructions.


Overtime for Employees Subject to Personnel Act (SPA)
Some personnel in (SPA) positions must be paid time-and-a-half for hours worked in excess of forty (40) hours per week. The Office of Human Resource Services should be contacted before hiring a person already on the payroll.


Payment in Excess of 100% to Employees Exempt from the Personnel Act (EPA)
During the contract period, no EPA employee may be hired to work on a grant if that effort results in payment in excess of 100% of load unless he/she has received approval in advance from the sponsoring agency, the dean and the Provost for that overload. All EPA employees must be paid in accordance with their normal salary rate at the University regardless of the source of funds. The maximum excess that a faculty member can receive is 25% per academic year. (Refer to Policy No. 17 of the Contracts and Grants section for additional information).


Leave Benefits
Personnel paid from a sponsored program account receive the same leave benefits as personnel paid from other University funds. Faculty and graduate assistants/associates on academic year appointments do not accrue vacation benefits and are not eligible to take vacation during days they are on the payroll for a sponsored program fund.

Staff and fiscal year appointees are encouraged to utilize accrued vacation before the program’s termination date. If the contract or grant does not have sufficient funds to pay the accrued vacation, it is the responsibility of the employing department to provide the necessary funding. It is the responsibility of the principal investigator to ensure that these employees accurately report their vacation time prior to the project’s expiration.


Space Rental
In some cases a University department, school, or center may require rental space to house a sponsored project. If off-campus space is required, the Director of Contracts and Grants must be contacted early in the proposal stage to assure that University and State regulations are followed. If rent is charged to the Funding agency, then the off-campus indirect cost rate should be used.


Stipends
Stipends for fellows and trainees are permissible only on training or fellowship grants. Individuals working on research projects are considered employees and their effort must be reflected on the time and effort certification report.


Subcontract and Subgrant Effort
Some sponsored program projects require the University to collaborate with other institutions or contractors. Such effort must be defined in the proposal and approved by the sponsor agency in advance. Subcontract or subgrant documents must also be approved by the sponsor agency prior to finalization of any such agreement. During any programmatic discussions with potential subcontractors or subgrantees, financial commitments or arrangements must be coordinated with and approved by the Office of Contracts and Grants. As audits are generally required for all subcontracts, the University’s proposal must provide for the costs of such audits or contain assurances that the audit will be accomplished. Other universities are also subject to federal audit requirements and can generally provide needed audit information without the need for a separate subcontract audit. Contact the Office of Contracts and Grants for additional information and guidance on this requirement.

Except for the estimated cost for auditing a subcontract, all subcontract costs, regardless of their nature, are a composite direct cost as far as the University is concerned and should always be shown in the subcontract cost line of the proposal. Although it is expected that subcontract costs will be broken out and supported in the subcontractor’s proposal to the University, subcontract costs should never be intermingled with UNCG cost elements. Each subcontractor that includes facilities and administrative costs as part of their overall budget needs to provide a copy of their most recently federally negotiated facilities and administrative costs rate agreement.

Where it is known in advance that specific organizational entities are essential to and will collaborate on a sponsored project, it is customary that estimated costs to be included in the UNCG proposal be corroborated by an official proposal from that organization prior to submission of the UNCG proposal.


Supplies
Generally, grant and contract funds may be used to purchase supplies delivered on or after the beginning date of the project. Purchases made during the latter part of a project are subject to particular audit scrutiny and therefore must be sustainable from the view points of relevance and usefulness to the project. Failure to adhere to these stipulations can result in audit exceptions and costs disallowance. However, some sponsors restrict purchases to budget periods as opposed to multi-year project periods.

If supplies are not received prior to the termination of an award or contract, it will normally be necessary to utilize and charge the supplies to the continuation award, or to another active project which requires and can effectively utilize the supplies. Where the usage and charges for such supplies cannot be legitimately absorbed by another active project or departmental budget, prompt action should be taken to cancel outstanding orders and avoid the incurrence of a financial obligation not covered by an authorized budget.


Travel
Travel expenses are allowable if authorized and in direct support of the project. All travel reimbursements, both to University and non-University employees, are subject to State and University travel policies except in those few instances where more restrictive policies and limitations may be imposed by a specific award. Federal travel regulations will apply when required by federal contracts.

State and federal definitions of foreign travel sometimes differ. The State considers all travel outside the contiguous 48 states to be foreign travel. The federal definition normally is less restrictive and usually excludes Alaska, Hawaii, Canada, and U.S. protectorates from the foreign travel classification.

To facilitate the review, justification, and approval of foreign travel requests, a copy of the meeting brochure or letter of invitation to travel should be attached to the request.


Utility Services
Utility costs, such as heat, light, water, air conditioning and local telephone service are recouped through the indirect cost rate and are not considered as direct costs. In unusual circumstances, where inordinate amounts of such services are required for a project, it may be appropriate to direct cost these items. The Office of Contracts and Grants can assist departments in such circumstances.

Nature of the Agreement
Cost sharing or matching in grants and contracts are terms that are used interchangeably. Cost sharing can either be imposed by a sponsor as a condition necessary to receive their support for research or training, or it can be volunteered on the part of the University to demonstrate its commitment to a project. Once a proposal containing cost sharing, be it imposed or volunteered, is accepted by a sponsor, it is considered binding upon the University and requires written approval from the sponser to change. Cost sharing obligations must be kept within reason and must be capable of being fulfilled from acceptable resources available to the principal investigator such as chair/head of his/her department, dean of his/her academic unit, director of associated center/institute, the Associate Provost for Research and Public/Private Sector Partnerships, or the Provost and Vice-Chancellor for Academic Affairs.

Once an award is accepted by the University, the Principal Investigator is responsible for ensuring that any cost sharing commitments are met, and that all necessary documentation is provided to the Office of Contracts and Grants. Cost sharing or matching expenditures incurred or services rendered must occur during the period of the award and are subject to the same sponsor guidelines and regulations.

As the contribution of resources under an in-kind agreement is not under the control of the University, much care must be exercised before entering into such an agreement. Once in operation, in-kind contribution agreements must be monitored by the researcher on an on-going basis to ensure that the agreement is fulfilled. This is accomplished by obtaining an after the fact certification from the entity. Procedure 12 – Cost Sharing and Matching Funds Report explains this process.


Clarification of Terminology
Cost sharing or matching is that portion of the project or program costs not paid by the sponsor. There are three types of cost sharing.

  • Mandatory Cost Sharing is required either by federal statute or by the established policy of the sponsor.
  • Voluntary Committed cost sharing is in excess of any such mandatory cost sharing. It is volunteered to demonstrate the University commitment to a project. Voluntary commitments in proposals become required financial commitments if the proposal is funded.
  • Voluntary Uncommitted cost sharing is defined as over and above that which is committed and budgeted for in a sponsored agreement. More specifically, this is either additional time or resources provided by the researcher, which were not denoted in the proposal, towards completing the project.

Cash and In-Kind Contributions
Cost sharing from a University source is considered a cash contribution. Examples of cash contributions include the following:

  • Faculty time along with the associated fringe benefits and Facilities and Administrative Costs (if allowable by the sponsor) is the most commonly used matching item.
  • Directly related supplies and services.
  • Equipment
  • Un-recovered Facilities and Administrative Costs, if approved by the sponsor.

Non-cash contributions provided by a third party are considered an in-kind contribution. There are two types of in-kind contributions: internal and external.

An example of an internal in-kind contribution is:

  • A nine-month UNCG faculty member who is voluntarily working on a research project on campus during the summer without compensation.

Examples of external in-kind contributions include:

  • Time donated by advisory council members.
  • The value associated with the use of an off-campus meeting hall.
  • Sub recipient cost-sharing.

Guidelines
Commitments to cost sharing and matching should be held to a minimum and should not, without compelling reason, exceed 5% of total project costs. Regardless of the percentage, the ability of the University to meet the commitment from acceptable resources must be clear.

As part of the proposal review process, when a Principal Investigator (PI) plans to include either UNCG’s resources or external entities’ resources as cost sharing, this information is specifically identified in the budget and in Section 6 on the Internal Processing Form: Application for Grant, Contract, or Cooperative Agreement. It constitutes a formal commitment to the sponsor by the department head/chair, dean of the academic unit, director of the center/institute, the Associate Provost for Research and Public/Private Sector Partnership, or the Provost and Vice-Chancellor of Academic Affairs. In cases where the matching involves external entities, a letter of commitment from each entity and a detailed budget must be submitted with the proposal. Any variation from this process must be approved by the Associate Provost for Research and Public Private Sector Partnerships before the proposal can be processed. In those cases where the subcontractors are providing cost sharing, their budget needs to identify these commitments.

Once the application for grant, contract or cooperative agreement is funded by the sponsoring agency, UNCG is required to provide the stated resources listed as cost sharing and the same fiduciary responsibilities in expending these funds, as is done for the funds from the sponsoring agency.

The Principal Investigator is responsible for tracking and providing matching information to the Office of Contracts and Grants. Guidance, according to Federal regulations, regarding what is considered acceptable tracking and reporting of matching is addressed in Procedure 12 – Cost Sharing and Matching Funds Report.

There are many instances where the cost sharing requirements for an award will be satisfied either in part or entirely by an entity external to UNCG. Appendix 1– External Matching Contributor Certification provides a sample reporting form to be used by entities external to UNCG when generating and reporting matching information to UNCG.


Criteria for Allowability
According to the Office of Management and Budget (OMB) Circular A-110 definitions of cost sharing and matching, all contributions can be accepted as part of the recipient’s cost sharing when such contributions meet all of the following criteria.

  • Are verifiable from the records of the PI.
  • Are not being included as contributions for any other federally-assisted project or program.
  • Are necessary and reasonable for proper and efficient accomplishment of project or program objectives.
  • Are allowable under the applicable cost principles.
  • Are not paid by the Federal government under another award, except where authorized by Federal statute to be used for cost sharing or matching.
  • Are provided for in the approved budget when required by the Federal awarding agency.

Please note, in cases involving unrecovered indirect costs, they may be included as part of cost sharing or matching only with the prior approval of the Federal-awarding agency.


Changes in Committed Cost Sharing
When an application or proposal that contains cost sharing is awarded, UNCG is expected to meet the cost sharing requirement in that application or proposal. If at the time of award, the sponsor’s level of support is less than the University’s originally proposed budget, any original matching commitments offered by the University or external entities on behalf of UNCG should be re-considered for possible reduction or elimination from the award. This consideration is handled by the Office of Sponsored Programs. If during the life cycle of a project, conditions arise that make it impossible to satisfy the matching requirements, the Office of Contracts and Grants and the Office of Sponsored Programs should be informed of this fact by the Principal Investigator. The Office of Sponsored Programs is responsible for re-negotiating any reduction in the level of matching required by the sponsor. The Principal Investigator is responsible for eliminating any matching shortfall requirements.


Reporting of Cost Sharing or Matching and In-Kind
In order to assist the Principal Investigator in capturing the cost sharing information in accordance with federal regulation requirements, the Contracts and Grants Specialist Assistant will provide guidance. Please refer to the Contracts and Grants staff webpage for a point of contact. The following forms will be used as necessary: Appendix 1-External Matching Contributors, Appendix 3-Cost Sharing/Matching Brief, Appendix 4-University Salary Cost Sharing Certification, Appendix 5-Summary University Salary Cost Sharing Certification, and Appendix 6-University Non-Salary Cost Sharing Certification.

In cases where the origin of funds is not from a federal source, please consult with the Contracts and Grants Specialist Assistant to determine how the reporting requirements might vary.

Federal funding agencies require that institutions working on subawards under UNCG prime awards follow all of the rules and regulations that would apply if the award had been issued to them directly. As a prime recipient and a pass through entity of Federal awards, UNCG is responsible for monitoring the programmatic and financial activities of its subrecipients in order to ensure proper stewardship of sponsor funds. The UNCG subrecipient monitoring policy provides guidelines for this process.

This guidance will address institutional responsibilities and assist Principal Investigators and staff to ensure that, in addition to achieving performance goals, subrecipients comply with Federal laws and regulations and with the provisions of any agreements that govern the subaward. The Office of Contracts and Grants (CGS) may impose specific controls, as needed, for certain Subrecipients based on relevant risk factors.


OMB Guidance
OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR §200) (“Uniform Guidance”), specifically sections §200.330 and §200.331, requires prime recipients of federal funds to monitor sub-awards and to ensure subrecipients meet the audit requirements in Subpart F and use funds in accordance with applicable laws, regulations and terms of the award.


Risk Assessment
Prior to issuance of the sub-award, The Office of Sponsored Programs collects the Subagreement Assurances Form data that certifies the rates, cost sharing, IRB/IACUC, COI, and fiscal responsibility of the subreceipient. In addition, The Office of Contracts & Grants (CGS) completes a Risk Assessment to determine the appropriate level of monitoring and ensure monitoring and reporting requirements are incorporated into the sub-award document as needed.


Monitoring
UNCG will utilize two kinds of monitoring: (1) CGS performs cost review of invoices and making sure that the subrecipient institution complies with the auditing requirements of the OMB Circular’s, and (2) the PI making sure that the subrecipient unit at that institution is managing the subaward correctly.


PI / Department Administrator Responsibility
The Principal Investigator (PI) is responsible for monitoring the activities of the sub-recipient, and confirms that costs are appropriate and reported timely relative to the programmatic activity of the scope of work. The sub-recipient should submit progress reports, technical reports and other deliverables to the PI by specified due dates.


Post Award Sub-Recipient Monitoring Procedures
CGS will review the sub-recipient’s invoice(s) for the following:

  • Period of performance is within the contract period
  • Appropriate invoice format and level of detail
  • Signatures of the PI
  • Funds are available in contract
  • Cost Share documentation, if applicable

Related Forms

Equipment Definition
The Office of Contracts and Grants is responsible for establishing and maintaining accountability for equipment acquired under grants, contracts, and subcontracts for sponsored programs in accordance with sponsoring agency directives and University policy. Equipment, for purposes of the Fixed Assets System, is defined as non-expendable property that costs $5000 or more (including installation charges and freight), has a useful life of more than a year, is of non-expendable material and is not consumed. Sponsor definitions of non-expendable equipment may vary as to the acquisition cost threshold. Most federal sponsors will utilize the definition contained in OMB Circular A-21, i.e., an acquisition cost of $5000 or more per unit.


Proposal Specifics
Proposals for awards should specify the type and quantities of equipment required (as sponsor agency prior approval policies vary, listing of equipment in an award does not necessarily provide approval to purchase the equipment). More specifically, budgeted equipment must be in compliance with the specific rules and regulations of the sponsoring agency and applicable to the Office of Management and Budget Circulars governing the expenditure of funds. Before requesting any new equipment, the principal investigator (P.I.) must determine that equipment available to the University will either not meet the project’s property needs or is not available for use when required.


Condition of Equipment
The principal investigator assures that equipment received is as ordered and in good condition. Any discrepancies or damage should be immediately reported to the Purchasing Department.


Physical Control of Equipment
Responsibility for maintaining physical control of all equipment acquired under an award and safeguarding it against loss, damage, or unauthorized use, rests with the P.I. The P.I. should notify the Fixed Assets Office of any major changes in the location of equipment. Subcontractors or subgrantees are also responsible for compliance with equipment policies and requirements and will be so instructed in sub-award documents.


Transfer of Equipment
Equipment owned by the federal government or other sponsors is subject to transfer to another institution where approved and directed by the sponsor agency. A request for transfer of such property can originate with a researcher transferring to another institution and requiring such property in the pursuit of continuing research, or with the sponsor agency itself. Subsequent to a researcher’s decision to transfer to another institution, equipment purchases should be limited to those necessary to complete research at UNCG. Additional equipment necessary to continue research at the gaining institution should be purchased by that institution.

A transfer originated by a faculty member requires the advance approval of the appropriate department head, dean, Director of Contracts and Grants, Director of Sponsored Programs and in some instances, the federal or sponsor agency. Agency-originated disposition or transfer instructions do not require such approval. However, if agency-directed or contemplated transfers are likely to impair continuing research or training projects at the University, such considerations should be promptly brought to the attention of the agency through the Office of Contracts and Grants in an attempt to dissuade the agency from making said transfer.

Specific requirements and procedures for obtaining the necessary approvals to effect the transfer of government or other sponsor property are contained in Procedure No. 10: Equipment Management.

When new faculty members will be transferring equipment to UNCG, the department should promptly advise the Fixed Assets Office so that equipment can be decaled, place on accountability records, and insured.

Much of the property acquired on research or training awards becomes University (State) property upon acquisition or by subsequent vesting of title. Disposition or transfer of such property is subject to University and State policies as set forth in Procedure No. 10.

Any questions relative to these policies or to equipment on a federally-sponsored award should be directed to the Office of Contracts and Grants.


Sale of Property
Proceeds from the sale of equipment purchased in whole or part from federal funds should be credited to the federal research project from which purchased or to an active award from that agency. Sponsor policies relative to the disposition of such proceeds do vary and it is suggested that the Office of Contracts and Grants be contacted for further guidance.

General
Compensation for personal services covers all amounts paid currently or accrued by the institution for services of employees rendered during the period of performance under sponsored agreements. Such amounts include salaries, wages, and fringe benefits. These costs are allowable to the extent that total compensation to individual employees conforms to the established policies of the institution, consistently applied and provided that the charges for work performed directly on sponsored agreements is charged at the same rate as other sources. Charges to sponsored agreements may include reasonable amounts for activities contributing and intimately related to work under the agreements.


Purpose
Office of Management and Budget Circular A-21 requires effort certification for payroll distribution purposes for all payroll charges to federal contracts and grants of professorial, professional, or support staff. These Time and Effort Reports account for 100% of each individual’s effort even if he/she is part-time. Charges for work performed on sponsored agreements by faculty members during the academic year will be based on the individual faculty member’s regular compensation for the continuous period which, under the policy of the institution concerned, constitutes the basis of his salary. Charges for work performed on sponsored agreements during all or any portion of such period are allowable at the base salary rate. In no event will charges to sponsored agreements, irrespective of the basis of computation, exceed the proportionate share of the base salary for that period. This principle applies to all members of the faculty at an institution. Since intra-university consulting is assumed to be undertaken as a university obligation requiring no compensation in addition to full-time base salary, the principle also applies to faculty members who function as consultants or otherwise contribute to a sponsored agreement conducted by another faculty member of the same institution. However, in unusual cases where consultation is across departmental lines or involves a separate or remote operation, and the work performed by the consultant is in addition to his regular departmental load, any charges for such work representing extra compensation above the base salary are allowable provided that such consulting arrangements are specifically provided for in the agreement or approved in writing by the sponsoring agency.


Time and Effort Reporting
OMB Circular A-21 requires that the payroll distribution system (time and effort reporting) will (i) be incorporated into the official records of the institution, (ii) reasonably reflect the activity for which the employee is compensated by the institution, and (iii) encompass both sponsored and all other activities on an integrated basis. The Office of Contracts and Grants is responsible for distributing, collecting, reviewing, and maintaining the official file of time and effort reports. The University has elected to use a system of after-the-fact activity confirmation reports for all employees paid partially or in full by one or more sponsored agreements. The percentages reflected on the time and effort reports are based upon the amounts charged to contract and grant accounts in the University payroll system, which may not reflect actual effort expended. The percentages must be changed to reflect the actual activity expended before they are certified.

A time and effort report is created each quarter for every University payroll which includes faculty, staff, graduate assistant, student or temporary salaries charged to sponsored agreements. The distribution of salaries and wages is based on payrolls documented in accordance with the general accepted practices of colleges and universities. The reports are sorted by department, based on the department to which the sponsored agreement is awarded. Certification of the effort requires that the person signing the time and effort report, whether it be the principal investigator, department head, or dean, have first-hand knowledge of all the employee’s activities during the reporting period. The information certified by departments, on a quarterly basis, for pay periods reflects the actual activity of each employee as well as it can be measured, not the budgeted activity. The reports confirm, on a best-judgment basis, that the percentage distribution of effort for the period reported produce an equitable distribution of charges for employee’s activities and serve to substantiate the distribution of costs on a consistent basis so that federal agencies are charged at the same rate as other sources for the same faculty/staff time.

Refer to Procedure No. 8 for more information on Certification of Effort Reporting.

Federal funding agencies require that institutions working on sub-awards under UNCG prime awards follow all of the rules and regulations that would apply if the award had been issued to them directly. As a prime recipient and a pass through entity of Federal awards, UNCG is responsible for monitoring the programmatic and financial activities of its sub-recipients in order to ensure proper stewardship of sponsor funds. The UNCG sub-recipient monitoring policy provides guidelines for this process.

This guidance will address institutional responsibilities and assist Principal Investigators and staff to ensure that, in addition to achieving performance goals, sub-recipients comply with Federal laws and regulations and with the provisions of any agreements that govern the sub-award. The Office of Contracts and Grants (OCG) may impose specific controls, as needed, for certain Sub-recipients based on relevant risk factors.


OMB Guidance
OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR §200) (“Uniform Guidance”), specifically sections §200.330 and §200.331, requires prime recipients of federal funds to monitor sub‐awards and to ensure sub-recipients meet the audit requirements in Sub-part F and use funds in accordance with applicable laws, regulations and terms of the award.


Risk Assessment
Prior to issuance of the sub‐award, The Office of Sponsored Programs collects the Sub-agreement Assurances Form data that certifies the rates, cost sharing, IRB/IACUC, COI, and fiscal responsibility of the sub-recipient. In addition, The Office of Contracts & Grants (OCG) completes a Risk Assessment to determine the appropriate level of monitoring and ensure monitoring and reporting requirements are incorporated into the sub‐award document as needed.


Monitoring
UNCG will utilize two kinds of monitoring: (1) OCG performs cost review of invoices and making sure that the sub-recipient institution complies with the auditing requirements of the OMB Circular’s, and (2) the PI making sure that the sub-recipient unit at that institution is managing the sub-award correctly and the costs are in line with the scope of work or deliverables submitted.


PI / Department Administrator Responsibility
The Principal Investigator (PI) is responsible for monitoring the activities of the sub‐recipient, and confirms that costs are appropriate and reported timely relative to the programmatic activity of the scope of work. The sub‐recipient should submit progress reports, technical reports and other deliverables to the PI by specified due dates.


Post Award Sub‐Recipient Monitoring Procedures
OCG will review the sub‐recipient’s invoice(s) for the following:

  • Period of performance is within the contract period
  • Appropriate invoice format and level of detail
  • Signatures of the PI
  • Funds are available in contract
  • Cost Share documentation, if applicable

Related Forms


Definition
Program income is the gross revenue earned from activities for which the direct costs have been charged to a grant (or subgrant) or counted as a direct cost toward meeting a cost sharing or matching requirement of a grant.

Examples of program income are:

  • Fees for services such as laboratory drug testing or conference fees
  • Proceeds from sale of equipment or supplies purchased or constructed with grant funds if title does not vest in the grantee
  • Usage or rental fees charged for use of facilities or equipment such as computer use charges or copy charges
  • Funds generated by the sale of commodities such as sale of tissue cultures, cell lines or research animals
  • Third party patient reimbursements for hospitals or other medical services where such reimbursement occurs because of the grant supported activity
  • Patent or copyright royalties

Depositing Program Income
The Office of Contracts and Grants should be contacted at the time it is recognized program income will be generated. They will assist in establishing the proper method of accounting for the income. Since program income has the same accountability requirements as federal grant funds, Contracts and Grants will select a mechanism which will account for program income in accordance with federal requirements.


Reporting Program Income
Program income, in accordance with specific agency requirements, is reported to the sponsoring agency on financial reports which are prepared periodically.

Facilities and Administrative (Indirect) Costs
Unless prohibited by the funding agency, all requests for extramural funding must include facilities and administrative costs. Effective November 23, 2010, UNCG negotiated a modified total direct cost (MTDC) method of calculating facilities and administrative (indirect) costs, please see Federally Negotiated Facilities and Administrative Costs Rate. Modified total direct costs includes all salaries and wages, fringe benefits, materials, supplies, services, travel, and the first $25,000 of each subgrant/subcontract. Modified total direct costs excludes equipment, capital expenditures, charges for patient care, tuition remission, rental costs of off-campus facilities, scholarships and fellowships, and the portion of each subgrant/subcontract in excess of $25,000.

Facilities and administrative costs reimburse the University for laboratory and office space; utilities; administrative services (e.g., purchasing, accounting, research, administration, personnel, security); custodial services; and building, grounds, and street maintenance. In other words, they include all those things essential to support sponsored research which cannot be broken down and directly charged to a specific grant or contract. Facilities and administrative cost percentages are determined annually from actual cost records through a detailed cost accounting procedure and are audited and approved by the federal government. Although the rates may be revised where the sponsor administratively limits facilities and administrative cost recovery, they are not subject to arbitrary adjustment either by the University or the sponsor.

There are organizations which, by regulation, limit facilities and administrative cost recovery. If the proposal is being submitted to such an agency, a copy of their policy must be submitted to the Office of Contracts and Grants with the proposal, if a copy is not already on file.

The University has separate facilities and administrative cost rates for research performed on and off campus. Based on the terms of UNCG’s federally negotiated Facilities and Administrative Costs agreement, the off-campus facilities and administrative cost rate applies to all activities performed in facilities not owned by the institution and to which rent is directly allocated to the project.


Overhead Receipts Allocation
The University has adopted an overhead receipts allocation policy that returns 10% of the overhead revenues to the principal investigator. This allocation policy is based on prior year’s revenues. Therefore, 10% of the revenues earned in the current fiscal year will be available to the principal investigator in the next fiscal year. The total allocation is:

  • 10% | Principal Investigator
  • 10% | Department Head
  • 80% | Provost recommends allocation to the Chancellor

Affirmative Action
All full-time appointments of over six months’ duration (including those funded by grants and contracts) are subject to the University’s Affirmative Action Plan and must be recruited for under search procedures. Recruitment for a position cannot begin until an initial search report is filed in the Office of Human Resource Services and signed by the University Affirmative Action Officer.

Exceptions to this policy may be made by the University Affirmative Action Officer only in the case of principal investigators and co-principal investigators who, as a condition of the award, must be named in the proposal. To request an exception under Affirmative Action for a PI or co-PI, the head of the employing unit should submit a letter, addressed to the University Affirmative Action Officer. This letter should be routed to the Office of the Provost, where it will be co-signed and forwarded to the Office of Human Resource Services.


Time Limited Appointments
Normally, positions under contracts and grants are time-limited and for a stated definite term. Otherwise, an employing unit has a continuing obligation to the person after the end of the funding period. During the recruitment period, the principal investigator will be advised by staff in the Office of the Provost and/or the Office of Human Resource Services about how to describe the position to interviewees.

As prescribed by the Office of the Provost for matters regarding pay beyond contract for Extramural Funded Research, please refer to The Policy on Compensation Beyond Contract for EPA Faculty and Nonfaculty Employees for The University of North Carolina at Greensboro as approved by the Board of Trustees, September 29, 1994.

Most awards to UNCG are on a cost-reimbursable basis. However, under some circumstances a fixed-price contract may be negotiated.

In those few cases where an agreement is a fixed-price contract (generally research institutes and centers), provisions must be made by the Principal Investigator (PI) and/or department or center having primary responsibility for the project to cover any overdrafts or excess funds.

Upon completion of the project and confirmation from the sponsor that the terms of the contract have been satisfactorily met, the facilities and administrative (F&A)/(indirect) costs budget will be adjusted to charge the contract the full F&A budget, subject to availability of the excess funds. Any remainder after covering the adjusted F&A costs will belong to the PI and/or department or center having primary responsibility for the project.

Procedures

The Office of Sponsored Programs (OSP) is responsible for the administrative coordination of review, approval and reporting of proposals for external funding involving UNCG. Several review procedures for proposals have been established by the President of the University of North Carolina. The Director of Sponsored Programs and the Associate Director have been authorized by the President to sign proposals and accept awards on behalf of the Chancellor.

In addition to research proposals, any contract or agreement for external commitment of the University (e.g., internships, service programs, exhibitions, etc.) must be reviewed by OSP prior to submittal to a potential funding source. The Director and/or the Associate Director will also provide or coordinate certification of compliance with Federal legislative requirements having to do with civil rights, handicapped access, human and animal subjects, drug-free workplace, etc.

General Overview of Proposal Processing as it relates to The Office of Research Services
The Office of Sponsored Programs can provide guidance regarding preparation and submission of research proposals.


General Overview of Budget Preparation as it relates to The Office of Contracts and Grants
The Office of Contracts and Grants can assist you with any budgetary matters as they relate to the proposal process. Contingent on your specific needs, the review of the budget and budget narrative can be simple and quick or can require an extensive review. You may initially want to discuss methodology regarding how to prepare a budget, specific agency requirements and whether or not matching should be included as part of your overall budget, and schedule a second meeting for a review of your draft budget. For more routine proposals, you might just need the final budget and budget narrative reviewed. In this case, please submit your proposal at least three working days in advance of the sponsor mailing date. Otherwise, it is recommended that if you need assistance you seek guidance from The Office of Contracts and Grants in the “preliminary/draft budget” phase. Please call us at 334-5091 and schedule an appointment and for us to review your budget. As a means to better serve you, it is preferred that you e-mail in “advance” a copy of your abstract, budget narrative and an electronic budget spreadsheet.


Proposal Budget
As you prepare your budget estimates, please refer to Appendix No. 2 for statistical information to be used in budget proposal preparation. Estimates should be prepared for the total cost of the project with the breakdown of the cost per year. Please note that filing a MODULAR budget with a given agency does not eliminate UNCG’s requirement to prepare a detailed budget and budget narrative. Please take into consideration the following information as you prepare your budget:

  • Salary: This line item should list all positions taking part in the project, the salary figure and the percentage of time each is expected to devote to the project and their names if known.
  • Fringe Benefits: Normally the sponsor requires these costs to be budgeted separately. Please refer to Appendix No. 2 for specific guidance.
  • Permanent equipment: Is defined as non-expendable property that costs $5000 or more (including installation charges and freight), has a useful life of more than a year, is of non-expendable material and is not consumed. See Policy No. 11, the equipment required should be listed with descriptions and justifications.
  • Travel – Note foreign travel normally requires agency approval and thereby needs to be specifically declared.
  • Other direct costs:
    • Includes In-State and Out-of-State Tuition , if paid via Financial Aid.
    • Food expenses are generally not an allowable use of federal funds. There are some noted exceptions to this rule. NIH says, “Meals are allowable for subjects and patients understudy only, or where specifically approved as part of the project activity, provided that such charges are not duplication in participants’ per diem or subsistence allowances, if any.”
  • Trainee costs: These can include a subset of costs such as stipend fees, travel, per diem, etc.
  • Subcontractors: A letter of commitment and a detailed budget is needed for each subcontractor, as well as a copy of their negotiated indirect cost rate.
  • Facilities and Administrative (F & A) Costs use to be referred to as Indirect Costs: In cases where the sponsor or specific program does not allow F & A costs, an appropriate source document such as a copy of program guidelines or an e-mail or a letter from the sponsor stating that they are not allowable is needed as part of the proposal package. In those instances where full recovery for F & A is not being proposed, authorization for a waiver must be obtained in advance. A request for waiver of F & A costs must be submitted to the Director of Contracts and Grants for approval by the Vice Chancellor for Business Affairs based upon the recommendation of the Provost.

Budgetary Considerations
Most university sponsored research and training effort is accomplished on a cost-reimbursement basis. Whether a contract instrument or grant instrument is used, UNCG is entitled to reimbursement only for costs allowable under provisions of Office of Management and Budget Circular A-21, Cost Principles for Educational Institutions, provided such costs are reasonable, clearly allocable and relevant, and have been accorded consistent accounting treatment. Research and training awards made to the University are subject to audit to confirm that expenditures were consistent with the purpose and time period of the award as well as other specified limitations. Failure to demonstrate compliance and provide sufficient documentation can result in audit disallowances. Award funds must be utilized solely for the purpose of the award and residual funds handled in accordance with sponsor requirements.

Once a proposal is submitted by the University to a sponsor, the only likely adjustment in funding requirements in subsequent negotiations is downward. Sponsoring agencies of all types, confronted with budgetary problems, consistently try to pare down the resources requested for research, training, or public service projects. It is essential that initial proposals incorporate realistic budgetary data for both immediate and future years of a project. If inflation, salary and wage increases, fringe benefits, travel costs, etc. are not adequately considered at the outset, there is little likelihood of additional funds being made available by the sponsor. This requires a reduction of effort in other areas and can be detrimental to the project.


Pre-Award Audit on Federal Contracts
If a federal contract is the mode of procurement and the University is either selected for the award or selected as a participant in final competitive negotiations, the sponosr agency usually requests a federal audit of the proposal cost estimate and the associated backup data on file in the originating department. It is essential that prepared data be retained and held available to justify the cost estimates submitted. Major grant proposals may also be subject to such an audit.

Preparation of the budget is, for some researchers the most difficult section of the proposal. Granting agencies see hundreds of proposals yearly and are proficient at comparing level of funding requested to the research work proposed. Therefore, it is important that the budget section of the proposal reflect, as accurately as possible, the funding needed to carry out the proposed research. Again, the investigator should not seek to overestimate the funds requested or to underestimate budgetary needs. Either of these strategies may lead to proposal rejection. However, a carefully prepared budget which details as accurately as possible the funds necessary to carry out the project described in the technical section of the proposal can be of major advantage in strengthening the total research proposal and can substantially increase the likelihood of funding. Furthermore, a carefully thought out budget can often identify weak areas in the proposal narrative and result in improvement of the technical proposal. The Office of Sponsored Programs staff can provide information on the amount of money awarded by various Federal agencies under past programs, whether or not an agency has increased or decreased levels of funding for the upcoming fiscal year, and special instructions which may update the program announcements or guides which the principal investigator may have on file.

The Office of Contracts and Grants’ staff can provide expertise in reviewing your budget and budget narrative. Contingent on your specific needs, the review of the budget and budget narrative can be simple and brief or can require an extensive review. You may initially want to meet to discuss methodology regarding how to prepare a budget, specific agency requirements and whether or not matching should be included as part of your overall budget. You might need to schedule a second meeting for a review of your draft budget. For more routine proposals, you might just need the final budget and budget narrative reviewed.

Regardless of the type of budget review you need, please submit the hard copy of your final proposal preferably two business weeks in advance, but no later than three working days before the sponsor’s mailing date for review and approval. As a means to better serve you, Contracts and Grants would appreciate it if you would e-mail at least two business days in “advance” of your budget proposal meeting a copy of your abstract, budget narrative and an electronic budget spreadsheet. Contracts and Grants recommends that if you need assistance you seek guidance from The Office of Contracts and Grants in the “preliminary/draft budget” phase of your proposal. Please call us at 334-5091 and schedule an appointment for us to review your budget.


A. Fiscal and Statistical Information
The basic statistical information used in budget proposals can be found in Appendix No. 2.


B. Direct Costs
In an effort to simplify your budget preparation process, please refer to the following line item budget information.


1. Salaries and Wages
Many sponsors require an estimate of the percentage of effort to be allocated to a project by each faculty or staff member. Regarding faculty time, the percentage of effort indicated and salary support requested must be reasonable and consistent with effort devoted to faculty duties and other sponsored projects. In some instances, a faculty member may propose to devote a percentage of effort to a federal project without charge thereto. Inherent in this commitment is a prior determination at the department level that an acceptable funding source, other than federal funds, will sustain the cost of the contributed effort. Contributed effort of this nature should be reasonable and capable of fulfillment without jeopardizing other commitments. Some federal agencies, such as the Agency for International Development and the National Institutes of Health, have placed ceilings on the annual salary rate assessable against agency awards. Waivers are difficult to obtain and a department must be prepared to absorb any unreimbursed amounts. Contact the Contracts and Grants Office for information about current ceilings.

To determine total salaries and wages, list the amount of time to be spent by each person who will be working on the project. Time should normally be shown in terms of a percent of full-time effort or as person-months . Show breakdown between summer and regular academic year.

The principal investigator may not schedule activities in excess of 100% of effort in any given month. As what constitutes a full course load varies contingent upon the school or center, the buy out rate per course varies.

Salary and wages rates cited in a proposal must be consistent with actual rates authorized and paid under University policy but should take into consideration known impending cost of living increases, promotions, merit increases, etc., and should include an allowance for such items in the budget estimates for the out-years of a project. Guidelines are set forth in Appendix No. 2.

University salary and wage policies, not the proposal budget, determine the rate ultimately paid an individual recruited for or assigned to positions budgeted in the proposal.

Compensation levels and new job classifications must conform to the policies established by the State Personnel Commission and should be cleared with the Office of Human Resource Services prior to submitting a proposal that includes new positions. Normally, include budget increments for professional and non-professional personnel on proposals extending more than one year. If specific increment figures are not available, estimate at 4% per year.

The maximum use of graduate students is encouraged. Graduate student payments should be consistent with those customarily paid within the department or college. Part-time (hourly-monthly) employees should be identified either as students or non-students.

Individuals employed in temporary positions (with special skills, for interview purposes, peak workloads, etc.) will be placed on the University payroll and therefore subject to federal withholding tax and FICA contributions.

Non UNCG faculty or staff members scheduled to participate in a research project should not be included under the UNCG salary and wage category. Necessary explanatory notes should be included to delineate the key roles of such individuals without conveying the impression that they are UNCG personnel. Personnel costs for such individuals should be included under consultant or subcontract cost categories as is appropriate and consistent with the contractual arrangements to be utilized.


2. Fringe Benefits
Salaries and wages are subject to employer-paid fringe benefits such as social security, retirement, medical insurance, and unemployment compensation.

The fringe benefit rate is determined on an annual basis and may not remain the same in future years. Therefore, when preparing a budget, refer to Appendix No. 2 or call the Office of Contracts and Grants to verify the current rate.

Fringe benefits are not normally part of salaries and wages and normally should be budgeted separately.


3. Consultants
The use of paid consultants may be justified when the project calls for expertise of a well-defined nature for a fixed period of time. By definition, consultants are not employees of University of North Carolina at Greensboro. Consultants should be budgeted only for tasks where on-campus expertise does not exist or is not readily available. Normally, consultants are paid a consulting fee plus travel expenses. Many sponsors do not permit payments to consultants and some restrict or limit such payments. If in doubt as to the allowability of consultants or rates paid to consultants, consult the sponsor’s program literature or contact the Office of Contracts and Grants. When possible, identify the proposed consultant vitae for the consultant in the proposal. Note that fringe benefits are not calculated for consultants.

If consultants are used from within the University, this should be clearly delineated in the proposal with the names of consultants indicated where known. Intra-University consultation should be nominal and not of such a recurring or repetitive nature as to make it more properly considered a part of the normal salary and wage distribution process.

Consultant costs require thorough justification to the sponsor agency and are subject to individual agency limitations and approval requirements.

Associated with professional consultant fees are attendant travel costs which should be handled as follows:

If travel allowances for consultants are to be included in the payments for professional services, the associated travel requirements should be grouped as part of the Consultant Fee line and appropriate explanation and justification included.

Unlike state funds, where no breakout is necessary between fees and travel allowances, when paying a professional fee, all professional and consultant arrangements on contracts and grants must separately detail on the Contracted Personnel Services form the amounts paid for fees and for travel and subsistence. This is necessary to demonstrate that sponsor agency limitations on daily consulting rates have not been exceeded.

While consultant travel and subsistence allowance are not subject to usual travel settlement procedures, allowances should be consistent with University travel policies. Complete justification for any exceptions considered necessary should be included on the authorization form or attachment thereto.

Air fare authorized is based on tourist or coach class. Per diem subsistence rates cannot exceed in-state or out-of-state rates without justification.

If payment to a consultant includes travel and subsistence, the department must assure that lodging and meals are not also charged against departmental or other accounts. Reservations for housing arrangements made on behalf of a consultant should be made in the consultant’s name with specific instructions that the consultant is responsible for all related charges. Additional charges for lodging, meals or other travel elements are not allowable where a consulting payment includes a predetermined amount for travel and subsistence.


4. Travel
Most sponsors will pay domestic travel costs if requested. Reimbursement for travel expenses is subject to State and sponsor regulations. Each proposed trip should be itemized and should include cost estimates for transportation costs, number of days of travel, and per diem. However foreign travel normally requires agency approval and thereby needs to be specifically declared.


5. Permanent Equipment
Items proposed as equipment should clearly meet the definition of “equipment” as defined under sponsor agency guidelines. Items that do not meet the equipment criteria should be included in the supply category. Permanent equipment is generally defined by the State and most federal agencies as personal property having an acquisition cost of $5000 or more (including installation charges and freight) and a useful life of one year or more is of non-expendable material and is not consumed. For additional guidance refer to Policy No. 11. Budget all the equipment that will be needed to perform the proposed tasks including the estimated costs of freight and installation. Many sponsors will not support the purchase of general purpose office equipment or data processing equipment.

Project-related and necessary technical or scientific equipment is a permissible cost element in research and training proposals. However, there is increasing sponsor emphasis on justification. Department, school, or center equipment resources should first be considered before including equipment requests in a proposal.


6. Expendable Supplies
Normally, a research project will consume expendable supplies such as laboratory items, teaching aids, and office supplies. A reasonable amount should be budgeted for these items.

Faculty who anticipate the use of a particularly large number of research animals of an exotic type should consult with the Animal Care Facility to see whether the funds estimated will be adequate.

Funds requested for supplies should correlate with the type and scope of work and include a reasonable provision of escalation if budgetary planning for future project years is involved.


7. Publication Costs
Budget the anticipated cost of publishing the results of the research, keeping in mind that page charges may vary from journal to journal. Consider both page charges and reprint costs.


8. Computer Usage
Computer costs should be included as a budget item. If non-sponsor funded computer time is needed, arrangements must be made in advance. Should the proposed work require a substantial amount of computer services, scheduling arrangements should be made with the Office of Information Technology to avoid time conflicts and to assure the availability of services when needed. Current rates are available from the Office of Information Technology.


9. Subcontracts and Subgrants
Proposals which contemplate subcontracts to named subcontractors must be accompanied by a statement from the subcontractor of his/her intent to participate in the program if it is funded and signed by an authorized institutional officer. This offer should include a statement of work, an estimate of the time required to complete the work, and a proposed budget (including applicable facilities and administrative costs) as well as a copy of their most recently negotiated Facilities and Administrative rate. Subcontracts and subgrants are included in the “other direct costs” category of proposed budgets. The subcontractor amount includes both their direct and indirect costs.


10. Other Direct Costs
Consider, as appropriate, costs for copying, long-distance telephone calls, postage, reference books and materials, equipment maintenance, library search services, stipends or subject payments, and In-State or Out-of-State Tuition, if being paid to the student via Financial Aid. Food expenses are generally not an allowable use of federal funds. There are some noted exceptions to this rule. NIH says, “Meals are allowable for subjects and patients understudy only, or where specifically approved as part of the project activity, provided that such charges are not duplication in participants’ per diem or subsistence allowances, if any.”


11. Participant Support Costs
Participant support costs are direct costs for items such as stipends or subsistence allowances, travel allowances and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with meetings, conferences, symposia or training projects. Payments to UNCG students must be made via Financial Aid. Other participant payments must go through Accounts Payable (excluding University personnel).

For agencies such as the National Science Foundation, funds provided for participant support may not be used by grantees for other categories of expense without the specific prior written approval of the agency. Therefore, awardee organizations must account for participant support costs separately.


C. Matching Funds/Cost-Sharing
Some agencies require matching funds and/or cost-sharing. Matching funds are normally defined as cash (e.g. a percentage of the cost of a piece of equipment), whereas cost-sharing is usually in the form of contributed time and effort by the principal investigator and his/her associates. All requests for matching funds must be approved and identified by source in advance by the principal investigator’s department chair and dean. Cost-sharing commitments in excess of 25% of the investigator’s time and effort should be discussed with the Office of Contracts and Grants.


D. Facilities and Administrative (Indirect) Costs
Unless prohibited by the funding agency, all requests for extramural funding must include facilities and administrative (F & A) costs. There are F & A rates for on and off campus activities. Based on the terms of UNCG’s federally negotiated Facilities and Administrative agreement, the off-campus F & A rate applies to all activities performed in facilities not owned by the institution and to which rent is directly allocated to the project. UNCG is on a modified total direct cost basis. Modified total direct costs normally consist of all project costs less the following: student aid, off-campus rentals, maintenance costs, capital outlays and the portion of subcontract costs in excess of $25,000. Please note the federal negotiated facilities and administrative costs rate are subject to change. Researchers should be prepared to make adjustments in budgets for such changes and should contact the Office of Contracts and Grants for specific information.

Facilities and Administrative costs reimburse the University for laboratory and office space; utilities; administrative services (e.g., purchasing, accounting, research, personnel, security); custodial services; and building, ground, street and parking lot maintenance. In other words, they include all those things essential to support sponsored activity which cannot be broken down and directly charged to a specific grant or contract. Indirect cost percentages are determined annually from actual cost records through a detailed cost accounting procedure and are audited and approved by the Federal Government. Although the rates may be revised where the sponsor administratively limits indirect cost recovery, they are not subject to arbitrary adjustment either by the University or the sponsor.

There are organizations which, by regulation, limit or do not allow facilities and administrative cost recovery. If the proposal is being submitted to such an agency, a copy of their policy must be submitted to the Office of Contracts and Grants with the proposal, if a copy is not already on file. In those instances where full recovery for Facilities and Administrative costs is not being proposed, authorization for a waiver must be obtained in advance. A request for waiver of Facilities and Administrative costs must be submitted to the Director of Contracts and Grants for approval by the Vice Chancellor for Business Affairs based upon the recommendation of the Provost.


E. Types of Awards
There are three standard awarding instruments: grants, contracts and special research support agreements. Proposal budgets are normally prepared anticipating these award types. Most proposals are prepared, and awards accepted, on a cost-reimbursable basis.


F. Modular Budgets
Please note that filing a MODULAR budget with a given agency does not eliminate UNCG’s requirement to prepare a detailed budget and budget narrative. For example, proposals including modular budgets to the National Institute of Health can be requested in modules of $25,000 for all years of support. A typical modular application will request the same number of modules for each year. However, if you are requesting $125,000 in year one and $62,500 for years two and three an explanation is required. Thereby, making a detailed budget an essential part of the proposal process. For example, purchase of major equipment in the first year may justify a higher overall budget in that year, but not necessarily in succeeding years.


G. Conclusion
Most university sponsored research and training effort is accomplished on a cost-reimbursement basis. Whether a contract instrument or grant instrument is used, UNCG is entitled to reimbursement only for costs allowable under provisions of Office of Management and Budget Circular A-21, Cost Principles for Educational Institutions, provided such costs are reasonable, clearly allocable and relevant, and have been accorded consistent accounting treatment. Research and training awards made to the University are subject to audit to confirm that expenditures were consistent with the purpose and time period for the award as well as other specified limitations. Failure to demonstrate compliance and provide sufficient documentation can result in audit disallowances. Award funds must be utilized solely for the purpose of the award and residual funds handled in accordance with sponsor requirements.

Once a proposal is submitted by the University to a sponsor, the only likely adjustment in funding requirements in subsequent negotiations is downward. Sponsoring agencies of all types, confronted with budgetary problems, consistently try to pare down the resources requested for research, training, or public service projects. If inflation, salary and wage increases, fringe benefits, travel costs, etc. are not adequately considered at the onset, there is little likelihood of additional funds being made available by the sponsor. This requires a reduction of effort in other areas and can be detrimental to the project.

For the aforementioned reasons it is important to seek guidance from The Office of Contract and Grants early in the proposal process.

The Office of Contracts and Grants can provide expert help in the preparation of a formal budget. Of course, only the principal investigator knows the specifics of what and who is needed and how he/she plans to proceed. Once the principal investigator has some broad, general knowledge or plan, Contracts and Grants will assist him/her in finalizing a budget and processing a proposal.

Contract and Grant fund numbers are assigned by the Office of Contracts and Grants based on the source of funding in the award document.

Awards for less than the amount in the original proposal budget require adjustments in the budget prior to establishment of a fund. Revised budgetary data will be requested of the principal investigator or department and should be supplied without delay.

Generally, a copy of all award documents are received from the awarding agency by the Office of Sponsored Programs. This information is then forwarded to the Office of Contracts and Grants to establish a fund in the Banner Finance system.



Fund Statement (FYRWFDST) and Month-to-date Transactions (FYRWFMTD) reports provide monthly updated financial data on each fund. Budgets, expenditures, encumbrances and free balances for University funds are shown on the report by expenditure category and in total.

Monthly fund statements, month-to-date and year-to-date transaction reports are issued for each contract and grant fund. These reports are distributed to principal investigators via e~Print.

The reports will not necessarily reflect all expenditures or outstanding obligations as of the report closing date. Transactions involving departmental invoices such as copy charges, postage, telephone, etc. and in-state travel; are not encumbered and do not appear on the FBM931 Reports until they are paid. It is therefore necessary to consider such outstanding obligations in determining the actual financial status of any particular account.

The Fund Statement (FYRWFDST) and Month-to-date Transactions (FYRWFMTD) reports should be reviewed promptly and used in the financial management process for each fund. Fund balances should be continuously evaluated in regard to expenditure trends, new or continuing requirements, remaining project periods, etc. Prompt action should be taken when necessary to request budget revisions or to curtail project costs. It is imperative that funds not be overdrawn with a view towards making adjustments at a late date. This imposes an unnecessary administrative burden on all concerned, involves retroactive adjustments which require detailed and unequivocal justification, and exposes the University to audit criticism and probable cost disallowances. Reporting errors do occur and these should be resolved as soon as possible with the appropriate personnel in Financial Services. Please feel free to use The Office of Contracts and Grants as your initial point of contact. If we cannot resolve your problem, we will redirect you to the appropriate office.

Purpose
There is considerable variation in sponsor policies relative to approval authorities for budget revisions. Accordingly, sponsor agency guidelines and award terms must be consulted when revisions are contemplated. Budget revisions should be based upon the financial plan and cost trends for the award budget period involved. To the extent possible, budget revisions should reflect all necessary reallocations of resources that are foreseen through the end of the budget period. Revisions solely for the purpose of coping with near-term problems (e.g., a $35.00 overdraft in the supplies category) should be avoided. If resources in all categories are already substantially committed to known requirements, a budget revision can only serve to defer, not resolve, a financial problem. In such cases, reduction of the project scope and effort may be the only viable solution. Another but less likely possibility may be additional funding by the sponsor.


Content of Revision
Each budget revision should be limited to a single fund, such as 200016, 225019, etc., and can be submitted via email or via memorandum. Each budget revision requested should provide pertinent information found in Appendix 7.


Revisions Request – Requiring Sponsor Approval
If prior sponsor approval is required for a budget revision, the information, as noted in Appendix 7, will be used by the assigned Contracts and Grants Specialist to prepare an institutional prior approval request/audit trail document and draft letter to the sponsor for approval by the Associate Director. If approved, a draft of the letter to the sponsor will be emailed by the assigned Contracts and Grants Specialist to the principal investigator for review prior to release to the sponsor.

Budget requests not requiring sponsor approval are normally processed within a few days of receipt by the Office of Contracts and Grants.


Implementation of Approved Revision
When agency approval is received, the budget revision will be entered into the Financial Accounting System by the assigned Contracts and Grants Specialist and the principal investigator so notified.


Assistance
Problems or questions relating to budget revisions should be referred to the Office of Contracts and Grants.

All agencies making sponsored research, training, or public service awards to the University are requested to transmit all funds directly to the Office of Contracts and Grants. Occasionally, checks are erroneously addressed to principal investigators or departments. These checks should be forwarded immediately to the Contracts and Grants office for deposit.

Receipts from authorized fees and expenditure refunds are deposited by the principal investigator. Deposit codes are furnished to the principal investigator by the Office of Contracts and Grants. Monies must be deposited with the Cashier’s Office, 151 Mossman Building, no later than the next business day after collection. Deposit slips obtained from the Cashier’s Office are prepared as follows: amount of deposit, six-digit fund number plus account code, who the money was received from, the name of depositor, and a deposit description to help define the nature of the funds being deposited.

Authorized fees must be approved by the awarding agency. If approved, the collection of authorized fees must be handled in accordance with Policy No. 10 and Procedure No.8 of the Financial Services Section of the Policies and Procedures Manual.

Distribution and Signature
The Office of Contracts and Grants distributes Certification of Effort reports to the departments at the first of each quarter for the prior three months payrolls, to be certified and returned within ten (10) days after receipt. It is required that the certification be an original signature of the persons required to sign. The certification signifies that the signer has firsthand knowledge or sufficient verification of the services performed on each funding source. Usually the principal investigator will certify all work performed on his/her contract or grant. The department head or dean should certify the effort of the principal investigator. It is imperative that the principal investigators check the reports closely to verify that the persons listed did, in fact, work on that particular project.


Effecting Changes
Corrections to the Certification of Effort reports should be made on the report before returning them to the Office of Contracts and Grants. The percentages indicated on the Certification of Effort reports are based on the payroll system and reflect the percentage salary charged to each fund. These percentages do not always correctly reflect effort. One example is nine-month employees are paid in 12 installments. During the summer they are not working on the nine-month contract, but are being paid. If they are also being paid for summer research, that effort should be 100% rather than the split based on the payroll charges.

Another example of a correction is when a faculty member is given released time to work on a project. That released time would require a manual adjustment to the Certification of Effort report.

If the payroll charges are incorrect, rather than a correction of effort distribution, changes should be indicated on the Certification of Effort report and formalized through the submission of the appropriate personnel action form(s). Necessary changes are required to be promptly effected, normally within thirty (30) days.


Retroactive Changes
Retroactive changes must give full consideration to previous certifications on file, and must be documented and explained in a manner which unequivocally substantiates the propriety of the adjustment.

Changes of distribution of workload may not normally be made for any prior pay period. In the following exceptional situations, however, retroactive changes may be warranted:

  • When necessary to correct clerical and data entry errors.
  • When subsequent information is received indicating an incorrect original entry.
  • When required to properly charge non-federal funds for costs incurred in connection with an award that fails to materialize.
  • When closely related work is supported by more than one funding source, costs may be transferred from the originally charged fund to another fund, provided the cost is a proper and allowable charge to the receiving account and the inter-relationship between the accounts is fully explained in the request. If an over-expenditure is being transferred to another project, especially strong supporting evidence is required for approval.

Unacceptable Changes

  • When the change is for the purpose of utilizing unexpended funds of a federal award.
  • When the change is for the purpose of circumventing award restrictions.
  • When the change is for the purpose of avoiding a cost overrun by charging another, unrelated federal agreement.
  • When explanation merely states “to correct error”, “to transfer to correct project” or other similar insufficient reasons.
  • When a change unrelated to sponsored agreements applies to a closed fiscal year.

General Requirements
With few exceptions, agencies or organizations sponsoring University research or training projects require some form of financial and technical reporting. Reporting requirements vary in frequency, format, due dates, and detail. The Office of Contracts and Grants strives to prevent the imposition of unreasonable financial reporting requirements (negotiating more reasonable requirements when possible) and complies with all financial reporting requirements once a contract or grant is accepted. The office also monitors compliance with technical reporting requirements. Not only is timely technical reporting a specific requirement and a separate area of audit emphasis, delayed reports can result in withholding of sponsor payments and can jeopardize future awards from that sponsor.

Financial data included in a proposal is budgetary in nature and establishes the financial parameters for a project for both current and future fiscal years. Requests for financial support must be realistic and consistent with the planned scope of work. The budgetary content of each proposal must be reviewed by the Office of Contracts and Grants prior to release to the potential sponsor.

On multiple-year projects with federal agencies, the University is required (long before the current budget year is complete) to update the budgetary data previously submitted for remaining project years and to provide an estimate of funds which will remain upon completion of the current budget year. The federal agency uses this estimate (normally prepared by the principal investigator) (P.I.) to determine future fiscal year funding requirements and new funding necessary for the specific University projects. The Contracts and Grants Office can prepare this segment of the report with input from the principal investigator. Please keep in mind any residual fund balance must be prudently estimated. If the residual fund balance is under or over estimated, the future budget year will be distorted accordingly.


Interim Reports
Some sponsors require interim reports, such as monthly or quarterly, for purposes of tracking the financial status of the project and for handling reimbursements due the University. Contracts and Grants normally handles these interim billings or reports without requiring input from the P.I. or department unless matching is involved. The terms of the agreement will govern how frequently matching information must be gathered. If the terms of the award require matching that is not reportable, the Principal Investigator will be required to provide matching information each semester.


Final Expenditure Report
The University is required to submit a final report of expenditures generally 60 to 90 days subsequent to the termination of an award. All authorized expenditures and outstanding obligations must be determined and considered in preparation of this report. Accurate, timely, and complete input from the P.I. and department is essential to prepare this report.


Unrecorded Obligations
Certain obligations will not be reflected in the monthly FYRWFDST and FYRWFMTD reports until paid, sometimes one or two months after the obligation is incurred. Therefore, such obligations must be carefully controlled. Examples include duplicating charges, intra-departmental distribution of telephone tolls, photocopy costs, travel, temporary help and similar services not subject to the encumbrance system.

These obligations must be carefully controlled, particularly near the date of termination. Any obligations presented to the Office of Contracts and Grants after the final report of expenditures has been filed must be paid from a source other than contract or grant funds.


Close Out Checklist
A Close Out Checklist is forwarded to the principal investigator 60 days prior to termination of a contract or grant budget period. Please see Appendix 9 for a copy. After receipt, the principal investigator must bring to a close all expenditures for the budget period; and correct all problems associated with the grant, so that the final report of expenditures may be completed with minimum complication.


Responsibility of the Principal Investigator
The principal investigator should maintain detailed financial records for the sponsored project. These records are to be utilized when reviewing the University Monthly Financial Reports, and when performing any other required administrative duty.

The principal investigator is responsible for the timely submission of all required documentation during the grant period, e.g., Cost Sharing and Matching Funds and Effort Certification Reports.

The principal investigator is required to handle any problems associated with the grant within thirty to forty-five (30-45) days of termination. The Office of Contracts and Grants assists in any way possible, but the main responsibility for internal problem solving resides with the principal investigators. Examples of problems which might occur are: payment of outstanding obligations; overdrafts in expenditure lines; expenditures charged to incorrect lines; and preparation and approvals of budget revisions. In addition, there are occasional problems unique to a fund which must be resolved prior to close-out.

General
Budgeted equipment must be in compliance with the specific rules and regulations of the sponsoring agency and applicable to the Office of Management and Budget Circulars governing the expenditure of funds. Also, prior to the inclusion of equipment requests in a proposal, the principal investigator should determine if necessary and suitable equipment is already on hand and available for use at the University. This is particularly necessary where costly, specialized equipment is involved. Effective equipment utilization and minimization of new equipment requests can be a competitive advantage for the University in the pursuit of sponsor support for research and training projects.

There is a report available via e~Print that can assist the principal investigator in the screening process for equipment costing over $5,000.

A representative from Fixed Assets periodically visits departments to identify and tag newly-acquired equipment. The location of the equipment is ascertained and a serially numbered tag is affixed to each item to facilitate equipment identification, inventory, and reporting processes. Equipment purchased with federal funds is noted in the files until such time as title is transferred to the University. For equipment that is located in satellite offices, Fixed Assets sends the tag to the off-campus location to be affixed to the proper equipment.


Transfer of Equipment (from UNCG)
When a principal investigator plans to transfer to another university or institution at which a federal agency intends to fund existing and continuing research, a transfer of equipment may be necessary. Such transfers must be arranged and approved in advance of the desired transfer date in keeping with established guidelines. The Office of Contracts and Grants assists with the arrangements and approvals necessary to transfer equipment owned by the Federal Government. To determine ownership of the equipment in question (federal or state), a preliminary list of property should be provided to the Office of Contracts and Grants. The listing is reviewed and the ownership status of each item determined. Once determined, separate transfer requests must be processed for those items federally and state owned in accordance with procedures referenced herein.

At least 60 days in advance of the desired transfer date, a letter of request prepared by the principal investigator and addressed to the owning federal agency should be routed through the Department Head and the appropriate Dean or Director to the Office of Contracts and Grants. The purpose of this routing is to afford those persons an opportunity to resolve questions or to identify adverse impacts on other projects which may stem from the proposed transfer. Concurrences or non-concurrences should be set forth by separate letter or memorandum. The Office of Contracts and Grants endorses the request to the agency and forwards any information regarding adverse effects on other University projects. The final decision rests with the sponsor agency.

Sponsor agencies require a listing of property to accompany each request for transfer. At a minimum, the listing should include the item description, model number, serial number, UNCG decal number, unit costs, funding source used for purchase, and acquisition date. Equipment should not be removed from the campus or shipped until all required approvals have been received. Arrangements for shipment are normally made through the University Purchasing Department.


Transfer of Equipment (to UNCG)
When a principal investigator is employed by the University and plans to transfer equipment to UNCG for continuing federal research, a list should be submitted to the Office of Contracts and Grants. The listing should include the item description, model number, serial number, original cost, funding source used for purchase, and acquisition date. Once the items are delivered to UNCG, the Office of Contracts and Grants should be notified so that the location of the equipment can be recorded and UNCG decal can be affixed to each item. Adherence to this procedure is necessary to transfer accountability and permit necessary arrangements to be made for insurance coverage.


Theft of Equipment
Thefts of equipment should be reported promptly to the Public Safety and Police Department. All losses through either theft or fire should also be reported to the Purchasing Department, Office of Risk Management (for insurance purposes), to Fixed Assets, and to the Office of Contracts and Grants where federal property losses are involved.

General
In very exceptional circumstances, cash advances are made to principal investigators or designated administrative representatives for such purposes as nominal payments for Research Subject or Incentive Fees.


Application for Cash Advance
If a cash advance is deemed necessary to carry out research or training activities, a Research Subject Advance form (CGBANFIN-34) should be submitted to the Office of Contracts and Grants including a statement of justification, which should contain the following information:

  • Purpose of the funds
  • Justification of the amount requested
  • Physical safeguards (where and how funds are kept)

If a cash advance request is approved, the check request will be processed and a check payable to the Principal Investigator or custodian will be drawn through the regular accounts payable system. The check will be charged to a cash advance fund, fund number 148502-500101.


Reimbursement Process
Within 45 days of receipt, the cash advance funds must be replenished by completing the ‘Reimbursement ‘ section of the CGBANFIN-34 form, charging the grant fund number, and account 221330 (Research Subject Incentives). The original copies of all signed statements of participants who received subject/incentive fee payments must be attached to the CGBANFIN-34. A check charged to the contract or grant fund will be written payable to the Principal Investigator or Custodian of the fund to bring the cash advance back to the original amount.

Due to the HIPAA and confidential regulations, when an individual’s name cannot be used, C&G only requires a study subject number, dates of service and the following statement, when preparing a check request, petty cash reimbursement or gift card reconciliation: Detailed study subject records kept on file in department. It is the responsibility of the department to keep these records on file for audit purposes. When preparing the check requests for study subject expenses the original receipts are to be submitted with the check request.


Settlement of Cash Advances
As soon as the cash needs are complete, but definitely prior to award termination, the cash advance fund must be turned in to the Cashier’s Office. Cash and/or checks totaling the original amount of the cash advance must be deposited to fund no. 148502-500101 to clear the advance. Please send a copy of the deposit slip to C&G Office (Remember to include your name and grant fund on deposit slip).

When the University is required to participate in the costs of certain projects by either cost sharing or matching, the University must fund these contributions from sources acceptable to the sponsoring agency. Such cost sharing requirements are binding upon the University, and if not fulfilled, can result in a reduction of sponsor funding. Since these contributions are considered a part of the project’s costs, the University is responsible for maintaining reasonable documentation. Consequently, the University devised methods to accumulate the contribution of the University and/or external matching contributors. Refer to Appendix 3– Cost Sharing/Matching Brief , Appendix 4– University Salary Cost Sharing Certification, Appendix 5-Summary University Salary Cost Sharing Certification, Appendix 6-University Non-Salary Cost Sharing Certification, and Appendix 1-External Matching Contributors.

Appendix 4– University Salary Cost Sharing Certification, Appendix 5-Summary University Salary Cost Sharing Certification, Appendix 6-University Non-Salary Cost Sharing Certification, and Appendix 1-External Matching Contributors are the responsibility of the principal investigator. The purpose of these forms is to report and certify to the Office of Contracts and Grants the amount of contribution given by either the University or external contributors on the referenced project. The Office of Contracts and Grants uses these forms to report the University’s contribution to the funding agency.

These reports must be filed on the same basis as committed in the agreement. A separate cost-sharing brief (Appendix 3 – Cost Sharing/Matching Brief) will be issued at the time of the new funding award brief (Appendix 8 – Grant Award Brief.) Reportable versus non-reportable matching requirements will be identified. In those instances where there are non-reportable matching requirements, the principal investigator will be required to submit this information on a semester basis. It is very important that these reports be returned promptly. Upon receipt, the Office of Contracts and Grants reviews the report and notifies the principal investigator if there are any questions. For further information on Cost Sharing and Matching, refer to Policy No. 9.

Appendix Statements


What is cost sharing?
Cost sharing or matching is the portion of a project or program’s expenses that are not paid by the sponsor. It can either be imposed by a sponsor as a condition of its research or training support (madatory cost sharing) or it can be volunteered on the part of the university to demonstrate its commitment to the project (voluntary cost sharing).

At UNCG, the Office of Contracts & Grants tracks all cost sharing commitments in order to report them to the sponsor or maintain them in the grant files.


Why does this award include cost sharing?
Either: Because your proposal included cost sharing with a specific dollar amount attached to it. If cost sharing is included in a proposal that is awarded, the cost sharing becomes a required financial commitment on the part of the University, even if the sponsor does not require it to be reported in financial reports.

Or: Because cost sharing of either a specific dollar amount or of a percentage of the award is a requirement of the sponsor, regardless of costs detailed in the proposal budget.


Why am I receiving this information?
The Principal Investigator (PI) of an award is the one ultimately responsible for ensuring that all cost sharing commitments are met and that all necessary documentation is provided to Contracts and Grants. The details of the cost sharing requirements for this award are included in the “Cost Sharing Summary for PI” Excel document.

What are the common forms of cost sharing and what are the forms to fill out for each? Federal regulations for cost sharing require salary certifications for individuals working on the project and unique identification of any non-salary contributions.

  • Salary costs, the percentage of effort of faculty and staff contributed to project , that are funded by a source other than the sponsor, normally the regular university budget. A Cost Sharing Salary Certification form is used to confirm the percentage of effort on a monthly or semester basis.
  • Non-salary costs, such as travel, advertising, printing, contracted services, scientific supplies or equipment, which were necessary for the implementation of the project but were not a part of the sponsor’s award. A Cost Sharing Non-Salary Certification form, along with appropriate backup documentation, is used to confirm these costs.
  • Unrecovered indirect costs for the grant – that is, the amount of IDC the University may charge, but that was not included as a part of the award. The sponsor must approve this cost sharing. These costs are calculated by Contracts & Grants, not by the PI, so there is no form to fill out.

What additional compliance information must I know?

  1. All cost sharing expenses must occur during the period of the award.
  2. All cost sharing expenses are subject to the same sponsor guidelines and regulations as the award expenses. (For example, if the sponsor would not allow alcohol as an expense, you could not cost share two cases of wine.)
  3. Cost sharing commitments for one project cannot be included in the cost sharing for another project.
  4. Cost sharing commitments for one federal grant may not be met by another federal grant.
  5. Untimely submission of cost sharing documentation to Contracts & Grants may lead to inability to meet cost sharing requirements by the project end date.

Please note a budget revision can be made via an e-mail request. Pertinent information that must be provided:

  • Names of: Principal Investigator, Project and UNCG Fund
  • Why you do not need the funds as originally budgeted?
  • Why you need to move funds?
  • The amount of funds being moved by line item.
  • If the budget modification involves an item(s) that are routinely treated as facilities and administrative (indirect) costs, please explain the direct research-relatedness for the item(s.) For example, a copy machine, desk furniture, or secretarial support is normally considered general administrative type expenses that are provided by your employer. Why should the sponsor pay for these expenses?

UNCG Fund Number:
Budget Period:
Budget Award Amount:
Project Title:
Sponsor:
Grant Origin:
Matching: Yes/No If yes, see separate matching award brief.

This is to summarize pertinent information concerning your program. If you have any questions regarding your fund balances, rebudgeting, policy interpretations or other administrative matters, please contact, (name) Contracts and Grants Specialist, at extension 4XXXX or via e-mail address ______________. If you have any questions regarding accounts payable issues, please contact Ralice Gertz, Accounts Payable Supervisor, at ext. 5740 or via e-mail address ralice_gertz@uncg.edu.


Fund Number
Please note the University’s identifying fund number. You are requested to cite this number with the proper account code on all University documents requiring an fund number.


Budget
Attached is a copy of your budget. Monthly financial reports can be accessed via e-print. However, it is your responsibility to contact the Office of Contracts and Grants to assure that your expenditure records correspond with our records. Please note that you must follow the University’s purchasing and accounting procedures, and you are responsible for all overdrafts. Please refer to the Policies and Procedures Manual for more details on the reports to be received and the proper accounting and purchasing procedures that must be followed.


Authorized Signers
Please e-mail the Contracts and Grants Specialist at _____@uncg.edu with names of any additional signers on this fund.


Purchase Orders
For Banner Financerequisitioning capability, please e-mail the Contracts and Grants Specialist with names of individuals for this fund. You must provide sufficient lead-time when submitting your purchase requisitions for the university purchasing process. Standard requirements less than $5,000 require 3-4 days. Requirements exceeding $5,000 must be formally bid by the Purchasing Department. Please allow 15 days for requests between $5,000 and $25,000. Requirements exceeding $25,000 must be posted to the Internet and require approximately 3 weeks.


Personnel
All personnel forms should be filed on a timely basis to ensure proper use of grant and non-grant funds. Please consult the web site for payroll processing deadlines.

See the Payroll web site for payroll processing deadlines.


Salary Documents
For the specific forms to be used or references to the appropriate offices to be contacted, in order to request expenditures to be made:

  • 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 (undergraduate and graduate) 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.