Procedures to Accompany University Policies on Sponsored Programs

Monitoring Direct Charges

The PI has primary responsibility for ensuring that charges to sponsored agreements are in accordance with federal, sponsor, and institutional policy. The department/unit and GCFA provide additional oversight; however, the department/unit and college share accountability for funds throughout the award life cycle.

a.    Principal Investigator

As the primary stewards of sponsored project funds, Investigators are expected to:

(1)    Maintain an understanding of federal regulations and institutional policies governing sponsored project administration, as well as any agency or sponsor-specific requirements outlined in the award documents;

(2)    Work with college/unit Sponsored Programs Office and GCFA to ensure that budgets are established in accordance with the federal regulations, agency-specific requirements, and institutional policies;

(3)    Review direct charges to his/her grants each month to ensure that the costs are:

• Reasonable, allowable, and allocable to the project;
• Within the performance period and directly benefit the project;
• Accurate and fully supported with sufficient documentation; and
• Within the limitations of the approved budget

(4)    Provide department/college with alternative funding sources in the event of a cost overrun or when unallowable charges are identified;

(5)    Review subrecipient invoices for the above-mentioned criteria and in accordance with additional requirements outlined in ; and

(6)    Monitor grant activity, expenditures, and fund balances monthly to ensure appropriate and maximum use of sponsored project funds.

b.   Department/Unit/College:  Financial Office and/or Sponsored Program Office

Together with the unit’s Sponsored Programs Office, the unit’s financial accountants are expected to:

(1) Maintain an understanding of federal regulations and institutional policies governing sponsored project administration, as well as any agency or sponsor-specific requirements outlined in the award documents;

(2)    Assist the PI in preparing the proposal and proposal budget in accordance with the federal regulations, agency-specific requirements, and institutional policies;

(3)    Assist investigators with interpreting federal cost principles and award terms;

(4)    Assist investigators in obtaining approvals from sponsors.

(5)   Monitor grant activity, expenditures, and fund balances monthly to ensure appropriate and maximum use of sponsored project funds.

(6)    Provide GCFA with alternative funding sources in the event of a cost overrun or when unallowable charges are identified;

c.    GCFA

GCFA is responsible for the fiscal administration of sponsored project and cost share funds. To reduce the risk of noncompliance with federal regulations, terms of the award, and institutional policy, GCFA will:

See Policy 3-0251

(1)    Establish financial controls to reduce the risk for unallowable charges to sponsored projects;

(2) Approve all purchases through procurement system

(3)    Assist Sponsored Programs Office with interpreting federal cost principles and award terms; and

(4)    Perform final grant closeout procedures.

e.     TO BE DETERMINED:

Monitor receipts from sponsor agency to ensure timely payment of invoices. If sponsor has not provided a timely payment, consider stop grant activity/expenditures.

After third notice, GCFA notifies college to consider stop grant activity/expenditures.