Sponsored Programs Administration Procedures
Table of Contents
- 1.0 Purpose
- 2.0 Scope
- 3.0 Designated Responsible Party
- 4.0 Definitions
- 6.0 Difference between Subrecipient and Vendor
- Subrecipient Monitoring
- Follow Up
- Distribution of Audit Report to Federal Prime Sponsors
- Subrecipient Invoicing Certification
- Operating Expenses
- Meal Policy
- Principal Investigator
- School Designee
- The Office of Sponsored Projects
- Contract and Grant Accounting
- The Budget Office
- The Subrecipient Monitor
This policy establishes The University of Texas at Dallas (UTD) institutional guidelines for Sponsored Programs administration. The policy complies with the requirements of the Office of Management and Budget (OMB) Circular No. A-21, "Principles for Determining Costs Applicable to Grants, Contracts, and Other Agreements with Educational Institutions", OMB Circular No. A-110 "Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations" and OMB Circular No. A-133 "Audits of States, Local Governments, and Non-Profit Organizations". The purpose of this document is to describe key aspects of Sponsored Programs administration to be used as guidance for faculty, management and staff in the performance of Sponsored Programs work.
This document includes the policies and procedures governing the financial administration of Sponsored Programs. It is applicable to all UTD departments, divisions and Schools with responsibility for the performance of internally or externally sponsored work and the associated administrative activities, such as: proposal preparation, negotiation of contracts and grants, budgeting and planning, preparation of documents, initiation and approval of Effort expenditures, Subrecipient monitoring, Subcontract document preparation, and the review and approval of Effort reports.
The designated responsible party (DNR) for the implementation of this policy is the VP for Research. The DNR ensures that education programs are developed to assist all faculty, administrators, and staff to fully understand the intent and the implications of this policy. In addition the DNR ensures that an effective monitoring process exists at UTD. The monitoring process is based on a Risk Assessment that identifies the internal controls to be relied upon, the monitoring strategies to be deployed, and how the results will be communicated to executive management. The DNR will work closely with the institutional compliance officer to ensure all specific risks are adequately mitigated and effectively monitored. The DNR shall file a report assessing institutional progress towards full compliance with this policy, to be submitted to the appropriate vice chancellor and the vice chancellor for research and technology transfer within 180 days after July 1, 2006.
Allowable Costs: Costs are considered allowable if they meet the following tests:
- They must be reasonable,
- They must be allocable to sponsored agreements, that is, they are incurred solely to benefit the sponsored project,
- They must be given consistent treatment,
- They must conform to any limitations or exclusions set forth in the Office of Management and Budget, Circular A-21 and in the sponsored agreement.
Budget of Effort Commitment: A perpetual detailed accounting of an individual’s expected Effort commitments for a given fiscal period (usually one year). This may include planned time for research, public service, instruction, administrative duties, and patient care (if applicable). Joint appointments between institutions are to be considered and included in the budget.
Cost Sharing: that portion of the total Project Costs that is not borne by the sponsor. These costs are usually borne by the University or other parties, rather than by the sponsor. Contributed Effort is considered Cost Sharing, as is faculty member’s salary above the federal agency salary cap level. The concept of matching is synonymous with Cost Sharing. Cost Sharing can be Mandatory or Voluntary and becomes a binding commitment to UTD upon either formal acceptance of the award document or expenditure of funds if no formal acceptance is required.
Cost Transfers: The transfer to or from a sponsored account of a charge that was previously recorded elsewhere or in the sponsored account. Cost transfers are usually used to correct errors and should be performed on a timely basis, should include proper documentation and should be approved by cognizant and authorized individuals. This policy only addresses Cost Transfers related to Effort commitments.
Committed Effort: The amount of Effort proposed in a grant or other project application that is accepted by a sponsor, regardless of whether salary support is requested for the Effort.
Effort: Effort is the proportion of time spent on work activities (instruction, research, administration, etc.), and is expressed as a percentage of the total institutional activity for which an individual is compensated by the University. It includes the time spent working on a sponsored project in which salary is directly charged or contributed (cost-shared Effort). Effort is not calculated on a 40-hour workweek or by any standard workweek. If an individual works a total of 80 hours in a given week, 80 hours represents 100 % Effort. If an individual only works a total of 20 hours in a week, 20 hours represents 100% Effort.
Effort Reporting/Certification: Effort reporting/certification is the federal mandated method of certifying to the granting agencies that the Effort charged or cost shared to each award has actually been completed. Effort reporting describes the allocation on an individual’s Effort.
In-Kind Contributions: Represents the value of non-cash contributions, which may be in the form of charges for real property and nonexpendable personal property, provided by the University and third parties, and the value of goods and services directly benefiting and specifically identifiable to the project or program.
Institution: An established organization, such as another university, corporation, or government agency.
Institutional Base Salary: Institutional Base Salary (IBS) is the total guaranteed annual compensation an Individual receives from UTD. IBS includes compensation for research, teaching, clinicians (applies to Callier center), patient care, public service, administrative duties, and/or other activities. IBS excludes fringe payments, administrative or reimbursed expenses, income earned outside of duties to UTD. IBS is based on permanent salary rates and does not include temporary payments. Individuals whose salaries are based on a nine-month appointment shall be annualized to twelve months to determine IBS. UTD faculty members are appointed for nine months, but can elect to have their salary paid over twelve months. These faculty salaries should be annualized to twelve months to determine IBS. UTD research scientists are appointed for twelve months and paid over twelve months.
Mandatory Cost Sharing: Cost Sharing contractually required by the sponsoring agency. Any cost share information contained in the proposal becomes a binding commitment to UTD, and is therefore considered mandatory. Mandatory Cost Sharing includes:
- Costs funded by the University from non-sponsored accounts, and certain non-federal sponsored accounts, and not included as Cost Sharing for any other sponsor project,
- Cash and third party cash contributions that are verifiable in the University's accounting system and are not included as contributions for any other federally assisted project or program,
- In-Kind Contributions contribution including volunteer services provided by professional and technical personnel, consultants and other skilled and unskilled labor if the services are an integral and necessary part of an approved project or program and are required by the award,
- Grant related income included in the approved project/program budget.
OSP: Office of Sponsored Projects, a UTD department with responsibility for preaward Sponsored Programs administration.
Pass-through: A portion of federal grant funds with a corresponding scope of work that are awarded by the primary recipient to another State of Texas University or agency.
Payroll Distribution System: the distribution/allocation of an individual’s salary. The Effort Certification report uses the Payroll Distribution System records as an initial representation of how Effort is allocated over activities during a particular reporting period.
System: the official UTD payroll system that distributes salary to the various accounts and/or grants. This distribution is based on the assignment of personnel using the Human Resources Personnel Action Form (PAF). The PAF is an official UTD form.
Principal Investigator (PI): The individual responsible for the management of the contract or grant. A designee can be assigned responsibilities by the PI to perform on their behalf, but the accountability can not be delegated and will reside with the PI.
Prime/Primary Institute: The original recipient of federal or state funds. The institution that Subcontracts a portion of their work on to another entity.
Project or Program Costs: All Allowable Costs incurred by the University, both directly and indirectly, in accomplishing the objectives of the grant or other agreement during the project or program period. Project Costs include Mandatory Cost Sharing, which can be direct or indirect costs.
NIH Salary Cap: The amount of salary paid to an individual above which an agency will not reimburse an institution. It is the maximum annual salary amount that can be charged to certain federal contracts or grants for 100% Effort. This salary cap changes annually, and can be found at:
Any salary above the current salary cap is to be considered Cost Sharing.
School: A teaching and research program/division within UTD, which provides the disciplinary foundation of the university. UTD currently has seven Schools: (1) Arts and Humanities, (2) Behavioral and Brain Sciences, (3) Engineering and Computer Science, (4) General Studies, (5) Economics, Political and Policy Sciences, (6) Management, and (7) Natural Sciences and Mathematics.
Sponsored Programs: Sponsored Programs involve a specific commitment of time and can be funded either: 1) externally funded in which a formal written agreement, such as a cooperative agreement, contract, or grant is entered into by UTD and the sponsor or; 2) internally funded for which the activities are separately budgeted and accounted for with internal application of institutional funds. The program can be for research, training, and other public service activities. For externally funded programs, the commitment of time can either be paid by the sponsor or in case of Mandatory or Voluntary Cost Sharing the costs are covered with institutional funds. A Sponsored Program may be thought of as a transaction in which there is a specified statement of work with a related, reciprocal transfer of something of value.
Subrecipient: A third party organization performing a portion of UTD research projects or other Sponsored Program. The terms of UTD Subrecipient relationships are documented in Subgrant/Subcontract or consortium agreements.
Risk Assessment: The UTD formal process of assessing risk which includes determining the type and level of exposure and the levels of controls needed. The purpose of Risk Assessment is to identify opportunities for improvement in the various areas of Sponsored Program administration including the health and safety of UTD employees and UTD legal and financial obligations. Contact UTD Internal Audit/Compliance for details.
Total Institutional Activities: Total Institutional Activities are those activities for which an individual is paid by UTD. Common activities include administrative duties, instruction, patient care, public service, and research.
Voluntary Cost Sharing: Cost Sharing provided by the University in excess of Mandatory Cost Sharing requirements, or when Mandatory Cost Sharing is not required. Cost Sharing is voluntary when no documentation with Cost Sharing indicated has been sent to or submitted to the sponsor.
6.0 Difference Between a Subrecipient and a Vendor, per Office of Management and Budget Circular A-133
- Has a responsibility to carry out a portion of the grant program as defined in the Subcontract,
- Has its performance measured against the grant program objectives,
- Has responsibility for programmatic decision making,
- Has responsibility for adherence to applicable federal program compliance requirements.
- Provides goods and services within normal business operations,
- Provides similar goods and services to many different purchasers,
- Operates in a competitive environment,
- Provides goods and services that are ancillary to the operation of the grant or contract,
- Is not subject to compliance requirements of a federal grant or contract.
Vendor purchases are not to be charged to Subcontractor or federal Pass-through object codes, (6303, 6305, 6312, and 6313).
6.1 Sub-recipient Monitoring
he Subrecipient monitoring policy provides guidance to Principal Investigators and administrative personnel in monitoring federal flow-through funds in accordance with the OMB Circular A-133.
The A-133 requires review of all pending and executed Subcontracts with particular attention paid to scope of work statements (SOW), billing instructions, contact information, and amendment and modification sections. Monitoring Subcontracts entails:
- Applying Risk Assessment to Subcontracts (pre and postaward),
- Maintaining a tracking system for all Subcontracts (postaward),
- Monitoring invoices received from the collaborator (postaward),
- Obtaining and reviewing audit reports from collaborator (postaward),
- Performing random expenditure audits. (Desk review/On-site audits at the postaward stage),
- Assisting with closeout of Subcontracts (postaward).
NOTE: The Subrecipient Monitor will ensure that all Pass-through entity responsibilities are adhered to in accordance with the A-133 circular as described in the publication and OSP’s procedures for handling Subcontracts. These responsibilities can be reviewed on the following link. http://www.whitehouse.gov/omb/circular/a133/a133.htm#d
- Financial Assistance:
- provides support or stimulation to accomplish a public purpose (can be issued as a grant or cooperative agreement)
- purchase of goods and services to accomplish a government purpose; service can include research (issued as a contract)
- generic term for agreements issued under a contract or grant
- Subaward or Subagreement:
- a Subcontract for programmatic Effort, under a grant
- Vendor Agreement:
- a Subcontract for commercial goods and services, under a grant or contract
- the entity that receives a Subaward
- Recipient or Pass-through entity:
- the entity that receives federal funds and issues a Subaward
- Flow-through funds:
- monies that are passed from the primary Recipient to a secondary entity or Subrecipient
- Random sample:
- can be defined as one in which every component has an equal probability of being selected from the larger population of all components.
All federal Recipients are required to maintain and monitor each Subaward or Subrecipient supported by funds the institute receives from the federal government. All Subcontract documents shall describe applicable laws and regulations required to be followed by the Subrecipients. All Subcontracts expending federal funds of $500,000 or more in grant dollars must perform a fiscal year audit and should be monitored routinely by the primary institute in accordance with the A-133 circular.
The Prime Institute must ensure compliance with federal laws, regulations, contract and grant agreement provisions and that performance goals are achieved by the Subrecipients. The Subrecipient monitor’s processes include:
- Maintaining a tracking system for reporting findings and responses,
- Reviewing the evaluation of Subrecipient’s A-133 audit report,
- Evaluating suggested corrective actions for audit deficiencies,
- Reviewing and monitoring the Subrecipient budgets,
- Contacting the Subrecipient addressing any inquiries concerning the federal program (Protocol information, Institutional tax status, Negotiated F&A rates, Current Fringe rates, etc…),
- Performing site visit to observe operations and review financial records as necessary,
- Initiating performance reports when required,
- Providing technical assistance to Subrecipients when needed.
The Subrecipient Monitor will process an A-133 audit letter to each Subrecipient, requesting verification of compliance status and documents of finding. The Subrecipient Monitor will document the Subrecipient file once a reply has been received from the Subrecipient. For those entities that do not respond, the Subrecipient Monitor will follow up until verification of audit has been completed.
The Subrecipient Monitor will review non A-133 Institutions that receive federal funds from UTD in the same manner as Institutions under the A 133 OMB circular’s guidelines. Detailed attention will be given to the following areas of concern:
- Experience level of the Subrecipient. Organizations with little experience in federal funding and regulations will require more training and oversight than those institutions with years of experience. Any institution, regardless of experience level, that consistently violates the guidelines will be considered high risk and monitored in accordance with UTD Subrecipient guidelines.
- Subrecipient organizational stability. What is the level of staff turnover? What are the current accounting practices? What other funding sources are available to the organization?
- Project complexity. By their very nature these programs require various consortiums to complete the research. Can this Subrecipient perform as a reliable partner in a complicated consortium research project?
Non A-133 Institutions will receive a Risk Assessment and ranking which will determine the frequency of monitoring.
Stage 1: Proposal/Preaward and “Just in Time”
Once preaward receives a proposal that contains a possible Subcontract, the specialist will notify the Subrecipient Monitor. An initial review of the Subcontract’s PI, institution, and the proposed budget will be conducted.
It is critical that an initial Risk Assessment be completed at the preaward stage of the proposed contract. This assessment will include:
- A review of past history of performance with that particular PI & Institution,
- Verification of A-133 audits,
- A review of SOW and proposed budget (verify calculation of F&A for both UTD and Subrecipient).
When the sponsors notify UTD of possible funding (Just in Time status) for any proposal with a Subcontract, the preaward specialist will notify the Subrecipient Monitor. The Subrecipient Monitor will start the secondary stage of the review process.
At the notification of possible funding of the proposal, the initial Subrecipient folder will be established. A recap of the initial stages will be completed and verifying of a fully executed Statement of Intent will be performed by the Subrecipient Monitor.
Stage 2: Processing the NOGA (Notice of Grant Award)
All awards containing Subcontracts will be forwarded to the Subrecipient Monitor. Preaward will copy the Subrecipient Monitor on the initial notification of award receipt. The Monitor will review the NOGA and document the following:
- Any restrictions listed in the NOGA,
- All budget reductions and how the Subawards are affected,
- All revised changes in the proposed project.
The Subrecipient Monitor will ensure that the Subcontract’s budget matches the award amount. The Subrecipient’s file will be updated, and the project will be flagged for desk review. The monitoring of Subrecipients will be conducted following the process below.
A random sampling of Subrecipient expenditures will be conducted on a routine basis. To determine which Subrecipients will be named on a particular list, the Subrecipient Monitor will select a specific expense object code. The Subrecipients identified by that account code will comprise that quarter’s sampling list. A different object code will be used each quarter until the limited set of codes begins to repeat. There is a possibility that one Subrecipient will be selected for sampling more frequently than others. Once that quarter’s list is compiled using the sampling, it will be used to conduct the required monitoring of each UTD Subrecipient receiving federal flow through funds as detailed below.
Stage 3: Postaward Processing and Monitoring
The Subrecipient Monitor will track all out-going contracts; audit invoices received; monitor budget compliance (any deviation that can possibly change the SOW); ensure that the collaborator sends the appropriate audit reports; and conduct proper Subrecipient monitoring audits. These tasks will be conducted on each Subrecipient receiving federal funds from UTD chosen during the sampling.
The Subrecipient Monitor will perform desk reviews of all Subrecipient’s reports and documents to verify the Subrecipient’s compliance with program requirements for this particular grant. The Subrecipient Monitor will utilize required periodic reports that are provided to the department and PI to help gauge completeness of the specific aims for that Subrecipient. Careful tracking and collecting of accurate data from the department and PI will be necessary at this point of the review. Items important to the success for this stage of the monitoring include:
- Progress reports,
- Cost Sharing records,
- Payroll records,
- Reimbursement records,
- Financial reports.
An accurate review of the reimbursement records and documentation by the Subrecipient Monitor will verify that the proper parties have requested the funds and that the funds are being used for program purposes. This is especially pertinent when the Subrecipient’s portion of the research contains a Subcontract within their proposed budget.
Actual visits to Subrecipient sites will be conducted on a priority basis as regulated by the A-133 circular. On-site visits will require that the Subrecipient Monitor travel to conduct the review of the Subrecipient’s performance. A checklist of activities and review items should be completed prior to the visit. The checklist will ensure that necessary compliance and control issues are addressed in the review. The on-site visit includes:
- Inspecting facilities to ensure compliance with program and regulatory requirements,
- Interviewing staff to assess their abilities to carryout the program policy and regulations,
- Reviewing documents and records (see postaward list above),
- Viewing delivery of program services (the process).
The Subrecipient Monitor will schedule the on-site visit with the Subrecipient after receiving approval from the Principal Investigator. The schedule will identify the dates and facilities to be visited. A copy of the program and schedule will be provided to the Subrecipient prior to the on site visit.
6.1.5 Follow Up
The Subrecipient Monitor will provide a copy of the review report to OSP and the PI. An official letter will be sent to the Subrecipient informing them of the results, and including all concerns and suggested changes. The Subrecipient Monitor will provide any technical support needed by the Subrecipient.
6.1.6 Distribution of Audit Report to Federal Prime Sponsors
When a Subrecipient fails to submit audit information to UTD, the Subrecipient Monitor should be able to find a copy of the Subrecipient’s audit report in the Federal Audit Clearinghouse. If not, the Subrecipient Monitor will contact the Subrecipient to obtain a copy of their report.
Upon receipt of each Subrecipient’s A-133 report, the Subrecipient Monitor will update the file and Risk Assessment form for that Subrecipient. The Audit Report will be logged into the central binder and retained for the appropriate length of time. For federal Subcontract agreements over $500,000, a copy of the audit report must be sent to:
Federal Audit Clearinghouse, Bureau of the Census, 1201 E. 10th Street, Jeffersonville, IN 47132
NOTE: For Subrecipients that are State of Texas Institutions, reviewing the Annual State Auditor’s Report satisfies the A-133 requirement. A copy of the report can be obtained from the State Auditor’s Office in Austin at (512) 823-4810. http://www.sao.state.tx.us/
6.1.7 Sub-Recipient Invoice Certification
All Subcontracts will require the following certification language on Subrecipient invoices. Absence of this certification will result in non-payment of Subcontractor invoices.
"I certify that the expenses represented by this invoice have been incurred in support of the work covered in this contract, and are in accordance with the provisions of this contract and all applicable federal and state laws and regulations."
The University cost sharing policy can be found at http://www.utdallas.edu/finace/grants/cost-sharing.html.
The following occurrences are indicator of poor award management and are a huge red flag to an auditor: volume of Cost Transfers, Cost Transfers that occur several months after the initial accounting transaction, Cost Transfers that occur after an Effort Certification report is completed, and/or a pattern of Cost Transfers from a sponsored project. However, since there are instances where a correction of a previously recorded cost is necessary, such transfers must occur on a timely basis. In addition to increased audit risk, the university may not be able to recover valid sponsored Program Costs if not recognized and reported on a timely basis. Cost transfers occurring after 90 days of the original transaction and/or exceeding five percent (5%) of the annual award, must be approved by the V.P. for Business Affairs.
For the above mentioned reasons, it is the university’s policy to keep the number of Cost Transfers to a minimum. Nevertheless, when a Cost Transfer is required, the following procedure will be utilized.
The Human Resources Personnel Action Form (PAF) is used to move salary expenditures from one account to another. This form initiates the transfer of the cost associated with an individual’s Effort. Cost transfers of Effort are to be created by the PI, or his/her designate, signed by an authorized signature for the account, forwarded to Sponsored Projects and then Contract and Grant Accounting for their review, checked for compliance with this policy, and then approved. The PAFs are then sent on to Human Resources, Budget, and ultimately the Payroll department. PAFs that effect grant accounts and do not contain Contract and Grant Accounting’s approval are not to be processed by Budget.
All grant Cost Transfers are to clearly indicate how the error occurred, and a certification of the correctness of the new charge by the Principal Investigator or the School Dean. “To correct funding or error” is not sufficient as a reason for the Cost Transfer. The justification should contain the name of the employee whose salary is being corrected, and the period being corrected.
The policy and procedure specific to Interdepartmental Transfers is BPM 20 and is located at:
Go to the “I” tab and click on BPM 20.
No Effort Cost Transfers will be permitted after Effort Certification reports are completed and signed by the PI, unless it benefits the sponsor (i.e. a transaction is moved off of a sponsored account).
No Cost Transfers of any kind are permitted after the Sponsored Program termination date or after the annual reporting date unless it benefits the sponsor (i.e. a transaction is moved off of a sponsored account).
Federal and state governments empower research institutions to manage sponsored projects funds with efficiency, effectiveness and accountability. The Office of Management and Budget Circular A-21 presents guidelines on what costs are allowable and can be charged to a sponsored project directly or indirectly. In addition, the Principal Investigator is responsible for ensuring that expenditures incurred on the project are within the scope of the work as determined and agreed upon with the sponsor and that all expenditures are in accordance with OMB Circular A-21 in that they are allowable, allocable and reasonable.
All fringe benefits, vacation pay (including termination lump sum payments), holiday pay, sick leave pay and other paid absences are to be charged to the current paying account(s), including sponsored accounts, in such a manner that each paying account pays its prorated share of the actual costs based on the Payroll Distribution of the salaries for each particular period.
9.2 Operating Expenses
- Operating expense type costs, which can be specifically identified to a sponsored project, should be budgeted, charged and reported as a direct cost to the project or Cost Sharing account,
- Service or recharge center charges must be based on actual utilization and cost-based charge rates,
- Telecommunication charges for academic departments required to support basic activities should be charged to the departmental accounts,
- Equipment and toll charges for phones needed for field sites, cellular phones while on travel status and large projects requiring dedicated lines may be charged directly to a sponsored account. These charges should be described in the budget and approved by the sponsor,
- The cost of postage, general offices supplies (paper, pencils, notebooks, etc.) and memberships should normally be charged to the respective departmental accounts,
- Postage and general office supplies can be direct charged to sponsored account when:
- The project requires a substantial amount of this item and it can be specifically identified
- The items are justified in the budget narrative and approved by the sponsor.
- Rent or lease expenses may occasionally be a direct charge to a sponsored project when:
- It is in lieu of hotel (travel) costs for long term field work
- Apartments are leased to provide lower-cost housing
- University owned space is not available for the completion of the project.
- Utility and Custodial Services may be considered direct costs when space is rented and the off-campus Facilities & Administration rate is applied,
- Motor vehicle maintenance expenses of project dedicated vehicles and vehicles used in the field may be charged directly to a sponsored project,
- Motor vehicle expenses incurred while on travel status may be directly charged to a sponsored project.
- Travel costs of University employees, which can be specifically identified to a sponsored project, can be a direct cost,
- Travel costs in academic departments, which are associated with the basic activities of the University, should be charged to the appropriate non-sponsored activity account,
- Foreign travel costs funded by federal Sponsored Programs must comply with the Fly America Act.
For information on charging food and refreshments to federal grants while not on travel status, see the following link: http://finance.utdallas.edu/grants/meal-policy.html.
- An item with a unit costs $5,000 or more and a life expectancy of more than one year meets the definition of equipment,
- The equipment item must be specifically identified and utilized on a sponsored project,
- Equipment must be purchased within the project period. Equipment purchased late in the project period may require approval of the sponsor,
- Equipment cost is excluded from the indirect costs (Facilities & Administration) rate calculation,
- Cost Sharing on equipment items must be in the form of an original purchase of equipment within the project period,
- The costs of previously purchased equipment cannot be included as direct Cost Sharing since it is considered to be part of the Facilities & Administration rate.
- The Principal Investigator has the following responsibilities:
- Ensure that the sponsor’s funds are being expended for the proposed and awarded scope of work and that the expended Effort complies with the applicable UTD policies and procedures and the sponsor’s governing regulations,
- Attend all training mandated by UTD,
- Work with the School division office to develop and manage all proposed and Committed Effort to eliminate any over commitments,
- Notify the School division office and OSP of new proposals and awards and the related additional Effort commitments,
- Maintain the appropriate records to be able to certify the Effort expended on Sponsored Programs under his/her control,
- Comply with university policy on the timing of Effort report Certification,
- Ensure the supporting documentation for Effort Certification is retained for five years after the end date or five years after an audit ends,
- Through proactive planning and communication, and timely account reconciliation, ensure, that the number of Cost Transfers, relating to Effort, are kept at a minimum,
- Ensure that all Effort Cost Transfers are done within the time limitations spelled out in this policy,
- Ensure Mandatory cost share accounts are opened and budgeted per this policy, and that only expenses that are allowable on the respective contract/grant are directly charged to it,
- The Schools have the following responsibilities:
- Develop Effort policies that faculty shall adhere to when calculating the minimum and maximum levels of Effort for faculty, researchers, and staff, per the guidance information contained in this policy,
- Appoint/assign an individual to work with and maintain Effort commitment budgets,
- To assure all financial records and supporting documentation related to the grant or contract are retained for five years after the end date or five years after an audit ends,
- Assist the PI in ensuring the number of Cost Transfers, relating to Effort are kept at a minimum, and that they are done within 90 days of the original transaction,
- Approve the Contract/Grant Certification form attesting to the appropriateness of the research proposal, the availability of the Effort commitments, and ensuring the individuals listed in the proposals are aware of their Effort commitment and have approved their participation in the activity.
- The School School designee has the following responsibilities:
- Develop and monitor the Effort “budgets” of expected Effort commitment for each PI, co-investigator, and key personnel being paid from a federal or state contract or grant. Total commitment cannot exceed 100%,
- Add new award Effort commitment data to the “budgets” upon receipt of the notice of a new award,
- Notify the PI, and School Dean, Sponsored Projects, and Contract and Grant Accounting whenever an individual’s total commitment exceeds 100%,
- Assure all financial records and supporting documentation related to the grant or contract is retained for five years after the end date or five years after an audit ends.
- The Office of Sponsored Projects has the following responsibilities:
- Notify the PI and the School Effort Reports Coordinator/designee of any new proposals submitted and new awards received,
- Assure all financial records and supporting documentation related to the grant or contract are retained for five years after the end date or five years after an audit ends,
- Administer all Effort Certification reports by providing the necessary reports which have been generated from the official university payroll system to the School Effort Reports Coordinators,
- Ensure the contract/grant account is not opened until after the Mandatory Cost Share account is opened and budgeted,
- Amend the cost share account budget if the awarded budget is less than the proposed budget, notify parties per this policy,
- Appoint a Subrecipient Monitor and notify this person of all new proposals submitted and new awards received that include a Subrecipient,
- Ensure all Subcontracts describe applicable laws and regulations that Subrecipients are required to follow,
- Ensure the requirement for the Subrecipient certification statement on Subrecipient invoices is included in the Subcontract,
- Ensure that budgeting for vendor payments are not allowed in the Subcontractor object codes.
- Contract and Grant Accounting has the following responsibilities:
- Ensure all financial records and supporting documentation related to the grant or contract are retained for five years after the end date or five years after an audit ends,
- Establish a process to ensure that salary caps established by sponsors are adhered to,
- Ensure that PIs or departments with an excessive number of salary Cost Transfers receives training to address the root cause of the transfers,
- Approve all Effort Cost Transfers on contract/grant accounts, ensuring that policy restrictions are adhered to.
- The Budget Office has the following responsibilities
- Ensure Contract and Grant Accounting has approved all Cost Transfers involving the account number ranges for federal and state contract and grants,
- Ensure all financial records and supporting documentation related to the grant or the contract are retained for five years after the end date or five years after an audit ends.
- The Subrecipient Monitor has the following responsibilities:
- Implement UTD policy on Subrecipient monitoring as reflected in this document by incorporating the selected provisions in the Subcontract documents and performing the annual Risk Assessments and the associated remedies to mitigate the risks,
- Document the Subrecipient monitoring procedures detailed in this policy,
- Notify the PI and OSP of any Subrecipient assessments that indicate a high risk.
Last Updated: August 8, 2012