Monitoring Expenditures on Sponsored Agreements – LR 214.3

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University of Arkansas at Little Rock
Policy Name: Monitoring Expenditures on Sponsored Agreements
Policy Number: LR214.3
Effective Date: February 8, 2016

Policy

In its efforts to adhere to all applicable guidelines, laws, and regulations related to expending funds on sponsored accounts, this policy provides general guidelines that address the proper justification and required approval of charges applied to sponsored accounts.

Definitions:

Principal Investigator/Project Director (PI/PD). A UA Little Rock employee who has primary responsibility for the conduct, reporting, fiscal, and programmatic administration of a sponsored agreement.

Sponsored Account. A fund set up to support a program/project funded by a grant, contract, or cooperative agreement under which the institution agrees to perform a certain scope of work, according to specified terms and conditions, for a specific budgeted monetary compensation.

Direct Cost. Costs that directly benefit and are specifically associated with a sponsored project or program.

Allowable Cost. To be allowable, costs must be reasonable and necessary; be allocable to federally sponsored projects under the principles and methods provided in OMB Circular A-21; be given consistent treatment; and conform to any limits or exclusions set forth in OMB Circular A-21 or the terms and conditions of the award.

Unallowed Cost. A cost determined to be unallowable in accordance with the applicable cost principles or other terms and conditions contained in an award.

Allocable. To be considered allocable an expense must be related to the project or incurred solely to advance the work under a sponsored agreement or benefit both the sponsored agreement and other work of the institution.

High-Value Purchases. These are supplies and/or services that cost at least $3,000 per requisition.

Foreign Travel. Travel outside the U.S. borders. Mexico, Canada, and U.S. possessions are considered foreign destinations.

Responsibilities

Principal Investigator/Project Director (PI/PD):

The Principal Investigator/Project Director (PI/PD) has overall responsibility for the fiscal management of a sponsored project while responsibility for the day-to-day management of project finances may be delegated to administrative or other staff.

Accountability for compliance with UA Little Rock policy and sponsor requirements ultimately rests with the PI. Accountability includes the management of the project within funding limitations, adherence to reporting requirements, and assurance that the sponsor will be notified when significant conditions related to project status change.

To authorize the expenditure of funds to be charged directly to sponsored projects, the PI/PD must assure that:

  1. The estimated charge is reasonable and necessary.
  2. The expenditure is allowable by the funding source and, if charged to a federally-funded project, is allowable by OMB Circular A-21.
  3. The expenditure is allocable to the project, i.e., benefits the project.
  4. The funds are available within the authorized award amount and funding limitations.
  5. The justification for the expenditure is documented.
  6. The method of allocation of costs is appropriate and documented.
  7. The charge is coded correctly.
  8. The charge has been processed through the appropriate university system.

Unit/Administrative Staff:

  1. Review and approve financial transactions for consistency with project purposes and the terms and conditions of the award.
  2. Assist PI/PD with university policies and procedures to complete transactions.

Office of Research and Sponsored Programs (ORSP):

  1. Review proposals for compliance with OMB circulars prior to submission.
  2. Ensure that all parties are aware of the institutional policies and processes as well as the requirements and obligations imposed by the sponsor when expending funds from sponsored accounts.
  3. Provide an “Unallowable Costs on Federal Awards” instruction sheet with each notice of award to PIs/PDs.
  4. Provide assistance with analysis and interpretation of award terms and conditions.
  5. Review and approve certain post-award transactions for consistency with award terms and conditions prior to purchase.
  6. Review expenditures for compliance with OMB circulars prior to submission of a request for reimbursement to the sponsor.
  7. Prepare and submit invoices and financial reports of expenditures.
  8. Close out funds, transfer overdrafts and unallowable expenditures to a non-federal source determined by the department and/or college, or adjust the budget to clear out unexpended balances after conferring with the PI/PD and unit administrative staff.
  9. Provide assistance to units that may be experiencing difficulties in the management of sponsored funds.
  10. Respond to sponsor audit requests.
  11. Conduct random post-audit reviews of selected expenditures and/or transfers of payroll and non-payroll expenditures for conformance to agency and university policies and procedures.

Procurement Services:

  1. Review routing and approvals of expenditures for appropriate approval prior to initiating purchases.
  2. Route purchases involving contract terms to the Contract Review Office.
  3. Distribute an “Unallowable Costs on Federal Awards” instruction sheet with each P-Card and CTS account.
  4. Provide annual training for P-Card and CTS users and include a representative from ORSP to facilitate training on the use of sponsored funds.

Procedures for Monitoring Expenditures on Sponsored Accounts

Source: http://www.whitehouse.gov/omb/circulsars_default; OMB Circular A-21 Cost Principles for Educational Institutions; OMB Circular A-110 Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations; OMB Circular A-133 Audits of States, Local Governments, and Non-Profit Organizations
Revised: March 10, 2015; February 8, 2016
Approved By: Chancellor Joel E. Anderson
Custodian: Office of the Provost