1 INTRODUCTION
The purpose of this manual is to set forth in one place many of the existing policies and procedures dealing with the administration of sponsored research and training projects for the University of Nevada at Reno. This manual is intended to expedite, and provide ease and consistency in the administration of sponsored projects. The information is a combination of existing policies and procedures for the University of Nevada at Reno, the Board of Regents, State of Nevada and major sponsoring agencies.
The university expects compliance with its policies and procedures as well as those of the sponsoring agency. Deviations will cause delays and confusion for all concerned and may result in audit disallowances by sponsors. At the same time, every reasonable effort will be made to accommodate special needs. The Grants and Contracts Office (GCO) should always be consulted concerning questions of either university or sponsoring agency policies or procedures.
The university in the fulfillment of its obligations to sponsors, students, employees and the public-at-large is expected to employ sound management practices and act with due prudence in all circumstances. When a sponsored project is accepted the university is responsible for complying with the terms and conditions of the agreement. GCO is responsible for coordinating all administrative and financial aspects of a sponsored project.
It is anticipated that revisions will be required periodically to comply with changing regulations and to provide additional assistance in those areas which may have been omitted from the initial publication. Faculty and staff suggestions for the improvement of this manual will be most welcomed and will receive careful consideration.
2 ORGANIZATION
The following outline demonstrates the division of responsibility that exists within the organizational structure for sponsored projects.
2.1 Pre-Award Activity
The proposal stage of the sponsored projects process is handled by the Office of Sponsored Projects Administration (OSPA). For details of the proposal stage please refer to the Faculty Guide to Sponsored Programs or call x4040.
2.2 Post-Award Activity
The award setup, management and close out of the sponsored project is handled by GCO. Their responsibility includes processing the award for the budget number in the College and University Financial System (CUFS). The Grants and Projects Analysts handle the administrative and financial matter reviews. The analysts act as liaison between principal investigators (PIs), university departments and the sponsoring agencies for the preparation of financial reports, cash management and the close out of the project. For details of the post-award process please call x4312.
2.3 Pre-Award Organization Chart
Chart 1 reflects the organizational structure of OSPA. A copy of the chart is included in Appendix 1.
2.4 Post-Award Organization Chart
Chart 2 reflects the organizational structure of GCO. A copy of the chart is included in Appendix 1.
3 GENERAL MANAGEMENT OF SPONSORED PROJECTS
3.1 Activating a Sponsored Project
A project can not be initiated or an account number assigned until official notification is received and the university formally accepts the contract. The chancellor or designee may officially accept a sponsored project on behalf of the university.
The process of setting up an account by GCO begins with the receipt of the setup package from OSPA. The package includes the award document from the sponsor, the transmittal and proposal along with the budget that the PI submitted to OSPA, which is co-signed by their dean and all related documents to manage the account. All packages that are not complete will be returned to OSPA. No obligations or expenditures will be allowed on a project until the setup package is received by GCO.
The setup package should contain enough information to set up the project. The budget form will identify the specific object codes. The account will be set up in CUFS and the PI notified. The maximum number of PIs that can be acknowledged by CUFS is two (2). A copy of form CONT-GC-03 is included in Appendix 2.
3.2 Activating Account without Prior Approval from Sponsor
This procedure is used only when it can be determined the eventual receipt of a sponsored project is certain. An account number will be assigned only upon receipt of a written request from the PI, which is co-signed by the dean or director of the research unit, to OSPA. A copy of form CONT-GC-17 is included in Appendix 2. This will trigger the setup package to GCO. The written request will indicate that the PI and the dean or director will be responsible for any expenditures made on the account in the event an official authorization is not ultimately received from the sponsoring agency. Therefore, all funds spent on the account will have to be reimbursed by the department if an award is not received.
If obligations or expenditures are disallowed by auditors because they are incurred prior to the official award date, such obligations or expenditures will be charged to the responsible party.
When this type of risk account is set up the PI and dean agree that it is a temporary account. There will be no invoicing of expenditures by GCO until the official award document is received. The general and special conditions of the award document determine who, what, where, when and how the invoicing will be done.
3.3 Project Period
All sponsored projects are funded for a specific period of time, generally referred to as the budget period or the project period. PIs are expected to accomplish the project objectives within the period of time.
Charges to a sponsored project are normally limited to expenditures or encumbrances incurred during the period of the agreement. Hence, expenditures or encumbrances may not be charged against a project prior to the start or beginning date nor subsequent to the ending date. A small number of agencies will allow expenditures and encumbrances outside the time frame only in special cases, which must be approved in advance. If the specific policy of the sponsoring agency is not known contact GCO for assistance.
Materials, supplies and equipment must be purchased with sufficient time remaining in the period so they can be utilized to benefit the project as proposed.
3.4 No-Cost Time Extension
If additional time beyond the established ending date is required for completion of the project, the PI will request a no-cost time extension from the sponsoring agency. Some sponsors preclude approval of a no-cost time extension unless the request is received by a certain time prior to the project ending date.
The request will include a brief statement of progress, a budget showing funds remaining and plans to complete that part of the project for which the extension is being requested. The need for an extension of time must be well justified. The fact that funds may remain at the ending date is not in itself sufficient justification for an extension.
Either the manager of GCO or the manager of OSPA should countersign this request. PIs are cautioned not to make commitments until the sponsor approves the no-cost time extension request.
Some sponsors have given the university the authority to extend the ending date of the project for special purposes. Remaining funds do not constitute a special purpose.
Contact GCO to see if this applies to your granting agency.
3.5 Multi-Year Sponsored Projects
Many agencies have established a technique whereby sponsored projects are approved for multi-year support, but are funded in annual increments called budget periods. The annual increments are generally noncompetitive.
If unexpended funds remain at the conclusion of a budget period, many agencies allow rolling over the funds into the next budget period. Do not assume this applies to every multi-year award. Contact GCO for clarification regarding this important issue.
3.6 Sponsor Contact
Oral communication with sponsors is necessary in order to clarify matters relating to the technical, administrative, programmatic or fiscal policies of both the sponsor and the university. The PI should always discuss it with the sponsor if matters relating to the technical and programmatic aspects of the project require clarification. Normally, discussions of this nature need not be relayed to GCO unless there is a change in the scope of work. However, when the discussions include administrative or fiscal matters, GCO must be informed and involved.
Discussions with the sponsor resulting in changes or modifications to previous requirements must always be documented in writing. All modifications to the original contract must be signed when necessary and must be routed through OSPA. Failure to secure the necessary signatures will cause delays, confusion and may result in audit disallowances.
3.7 Compliance with Sponsor Regulations
It is the responsibility of the university to comply with all policies, guidelines, rules and regulations established by sponsors under the terms of the award agreement accepted by the university. In the case of conflict between sponsor policy, the State of Nevada policy and the Board of Regents of the University of Nevada at Reno, the more restrictive policy will prevail.
It is the combined responsibility of the PI, Dean, Department Chair and OSPA to insure that the award document does not contain terms and special conditions with which the university can not comply. The PI should be familiar with the requirements imposed by the sponsor. These are usually outlined in handbooks, guidelines and the award document itself.
Normal reporting requirements will generally include progress reports, final reports and periodic project management and cost prediction reports. The PI is responsible for the preparation and submission of all required technical reports.
GCO will monitor for sponsored project rules, regulations, guidelines and policies. GCO will obtain clarification or interpretation of the sponsor requirements to serve as the source of information to other university offices and personnel involved with sponsored projects.
GCO is responsible for maintaining the official university fiscal records, which are used in the preparation of financial reports and are subject to audit by the sponsor. All correspondence concerning a sponsored project must be forwarded to GCO for inclusion in the project file.
3.8 Subcontracting and Subagreements
The need for a subcontract is normally anticipated during the proposal stage. The collaborative effort with other institutions result when their expertise is needed to fulfill the terms of the project. Subcontract costs included in the proposal and accepted by the sponsor in the award document are considered to be approved by the contract or grant officer.
Prior written approval is required from the sponsor if the need for a subcontract becomes necessary subsequent to the award. The subcontractor's complete budget and technical information will be appended to the PIs proposal. It must be signed by their official authority to enter into a contractual agreement for their organization. For sole source subcontracts, an explanation of the reason must be submitted. The subcontractor's proposal will include the following:
GCO will be responsible for preparing the official subcontract document. The subagreement will specifically state or incorporate by reference all applicable sponsor regulations, as well as those required by federal, state or local authorities. All assurances that are a requirement for the university must also flow to the subcontractor.
All subagreements will be made in the name of - The Board of Regents, University and Community College System of Nevada on behalf of the University of Nevada at Reno and the department for which the PI is doing the project. An authorized official of the university will execute the subagreement. No verbal commitments will be given to the subcontractor until a properly executed subagreement has been completed.
The PI is expected to maintain close contact with the subcontract agency for time schedules and to assure the quality of the performance. Before any invoices are approved for payment to the subcontractor, GCO will review the financial data and the PI will perform the technical review. Remember that payment of the invoices infers acceptance of the subcontractor's work. The subcontractor and the university are subject to an audit.
3.9 Rental/Lease Facilities and Equipment
The appropriate facilities and equipment shall be available for project activities. However, if this is not the case, rental and lease costs should be included in the proposed budget. The budget justification will also contain a detailed explanation of the need to rent or lease the facilities or equipment.
When considering the possibility of renting equipment, one should determine whether renting is more economical than purchase of the equipment. If the rental or lease cost exceeds the purchase cost, additional justification will be necessary when seeking sponsor approval. Most sponsors normally approve equipment rental when it is not practical to purchase the equipment due to the short duration of a project or the equipment is not otherwise available within the university.
3.10 CONFLICT Of INTEREST
University personnel shall not in any manner, directly or indirectly, receive any gratuities, commission, personal profits or compensation of any kind or nature inconsistent with loyal service to the public. Reference is made to OSPA Conflict of Interest policy and the Nevada conflict of interest laws, Nevada Revised Statutes, Chapter 281.
For more information refer to section 1,505 of the University of Nevada at Reno Administrative Manual.
3.11 Transfer Sponsored Project to another Institution
A change of grantee organization is the process whereby the legal and administrative responsibility for managing a project is transferred from one legal entity to another.
When a PI terminates employment with the university during a project the department chair and the dean of their unit has the prerogative to nominate a substitute PI or request that the award be terminated. The Vice President for Research will have the final authority. When a PI plans to transfer to another institution and their participation is integral to the project and the PIs original and new institution agree, the sponsor will facilitate a transfer of the project.
The transfer will normally be done with a tripartite agreement (involving the sponsor and the PIs original and new institutions) or by a subagreement arrangement (in certain circumstances) between the PIs original and new institution, subject to the sponsor’s approval. Contact GCO for the details.
Equipment purchased with sponsor funds for use on a specific project will remain available for use for the duration of the project. If the active project is transferred to another institution, the equipment purchased on the project will also be transferred. Shipping costs for such equipment may be charged to the original or transferred project as an allowable cost. Budgets can not include funds to "buy" equipment that had been previously obtained with sponsor funds.
The Property Office must approve all requests for equipment transfer.
3.12 Publications
Most sponsors encourage and in some cases require the publication and distribution of project results and accomplishments. Most sponsors will permit the cost of publication, including page charges, necessary illustrations and reprints to be charged to project funds, if budgeted accordingly. The sponsors require acknowledgement of their support in all publications, whether copyrighted or not. Most sponsors have either a required or suggested statement acknowledging support of a sponsored project. Most sponsors also require a disclaimer statement:
However, any opinions, findings, conclusions or recommendations expressed herein are those of the author(s) and do not necessarily reflect the views of the sponsor.
When issuing statements, press releases, requests for proposals, bid solicitations and other documents describing projects funded in whole or in part with federal money, the university shall clearly state:
Most sponsors also require copies of all articles relating to sponsored project results that are published in a scientific, technical, professional journal or publication.
3.13 Audit Information - Financial
The auditors will review the official university accounting records maintained by GCO. If a PI or department receives a request directly from an auditor for an interview or to review departmental records, GCO is to be contacted immediately.
GCO will cooperate fully with the auditors to insure all matters are resolved involving the audit. All phases of the audit will be monitored by the manager to insure that any problems needing attention are handled in a timely manner. In the event GCO can not answer or satisfy the auditor, the PI or departmental input may be necessary. For these occasions the PI will be notified prior to the meeting.
3.14 Audit Information - Programmatic
The PI and the department will handle all program audits.
3.15 Cooperative Research with other Institutions
Faculty members are occasionally invited by colleagues at other institutions to participate in projects, which have been or will be funded by sponsored awards to those other institutions. The normal procedure is to subcontract between the awarding institution and the university.
Should a faculty member participate in inter-institutional projects under these circumstances, a proposal outlining the extent of participation in the funding and facilities commitment necessary to carry out the participation will be prepared and submitted through the normal procedure. A copy of form OSPA-1 is included in Appendix 2.
This will provide an opportunity for the same type of review given proposals to primary funding sources and will assure the awarding institution of official university approval of the proposed collaboration. The faculty member will discuss fully with their dean and OSPA any proposed collaboration with another institution prior to making any commitments either personally or for the university.
3.16 Multiple-Sponsor Account
One account may be set up for multiple sponsors if all of the following criteria apply:
If all of the above apply to one program, then one account to handle multiple awards will be set up. Otherwise all accounts will be set up using our normal procedure.
3.17 Small Projects - Services
Certain projects to perform services for clients may be accounted for in a non-restricted account if all of the following criteria are met:
If the project does not meet all of the above criteria, the account will be set up using our normal procedure.
4 FISCAL MANAGEMENT OF SPONSORED PROJECTS
4.1 Expenditure/Accountability of Funds
The acceptance of a sponsored agreement indicates that the university has agreed to comply with all applicable terms and conditions of the agreement. Compliance with the award terms and conditions is a responsibility shared by all members of the university. The PI and the university are responsible for ensuring costs charged to a sponsored project are allowable, allocable and reasonable under the cost principles. The PI may authorize allowable charges to a project if the goods and or services are directly related to the project. The accuracy of the accounting records for the project depends on the assignment of the proper account numbers and object codes.
Salary and wages may be authorized by the PI only for effort which directly benefits the project and which is provided within the project time frame. Similar criteria must be applied to expenditures for services, materials, travel and equipment. Overtime pay is not an allowable charge unless authorized in advance by the sponsor. Also, equipment must be received in sufficient time to benefit the project. Supplies not consumed within the time frame of the project will be subject to inventory.
Projects frequently provide specific authorization and funds for publication of the results after the project has been completed. Such funds will not always be expended prior to the ending date. When this situation occurs the funds should be encumbered prior to the expiration date. If not, a no cost extension should be requested. Contact GCO for details.
The university is expected to conduct research and other project activities in a manner consistent with its own academic philosophies and institutional objectives. The university is further expected to employ sound management practices in the fulfillment of obligations for sponsored projects. Stewardship of public funds is an enormous responsibility that must be taken seriously.
Examples of general university responsibilities are:
4.2 Expenditure Object Codes
The university has established categories of expenditure codes that must be used when recording a purchased item through the accounting system.
It is noted the university, the State of Nevada and the sponsoring agency's expenditure codes may be different. Therefore, for sponsor fiscal reporting purposes the costs may have to be regrouped and reported in the sponsoring agency's budget categories.
The main expenditure groupings are:
Title Object Code
salary 11 thru 15
fringe benefits 16
travel 20
operating 30
participant support 40
subagreements 41 and 42
consultants 43
tuition and fees 44
equipment 60
indirect costs 89
Contact the Office of Accounting Services, x4164 for detailed object codes.
4.3 Accounting Records and Reports
The official accounting records of the university are maintained by the Controller's Office. The official accounting records will be used in the preparation of all financial reports and will be subject to audit by federal, state or private auditors. A status report will be sent to the departments each month for each sponsored project.
4.4 Departmental Records
GCO, in conjunction with the Controller's Office, maintains the official sponsored projects fiscal records. However, it is necessary for the PI and the department to maintain records for accounting purposes. The primary use of such records is to determine that all charges to a project are in fact applicable to that project. A copy of the official status report is provided to the PI on a monthly basis and should be reconciled immediately. The PI is responsible for all expenditures charged to the project. Erroneous charges should be reported to the appropriate administrative office as soon as possible so the charge can be properly accounted for.
With the proper security code for CUFS the PI is allowed to use inquiry to access their own accounts. CUFS is in real time not batch mode. The PI will be able to see which documents have been processed against an account. Monitoring each account is important to avoid purchase orders rejecting for lack of funds or trying to process a charge outside the project time frame. It will avoid delay, confusion and frustration by being able to have updated information to rely on.
4.5 Fringe Benefits
Fringe benefits are treated as direct costs. The university uses a fringe benefit rate, which is applied to salaries and wages in budgeting fringe benefit costs for project proposals. The actual cost of each fringe benefit is charged to the sponsored project.
The following fringe benefits are treated as direct costs:
Contact OSPA for rates for different categories of personnel.
4.6 Procurement of Materials or Services
Procurement on sponsored projects is made in accordance with the standard purchasing requirements of the State of Nevada. Some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action. Price analysis may be accomplished in various ways, including the comparison of price quotations submitted market prices and similar indicia, together with discounts. Cost analysis is the review and evaluation of each element of cost to determine reasonableness, allocability and allowability.
Procurement records and files for purchases in excess of the small purchase threshold shall include the following:
Requisitions for material and services from university sources (interdepartmental purchases) do not require the approval of the purchasing department. The Office of Accounting Services has the responsibility of processing these documents. For external sources there are several ways in which to requisition material and services. The limited purchase order (LPO) has a maximum dollar amount. They do not require the Purchasing Department's attention. The request for purchase order will flow through the purchasing department and will be reviewed for conformance with the State Purchasing Manual. Contact the purchasing department, x6552 for detail.
4.7 Travel
This category is for university system employees only. Most sponsors will pay travel costs if requested and justified. Reimbursement for travel expenses is subject to both university and the sponsoring agency regulations. Most sponsoring agencies require prior written approval for foreign travel. The travel section in the university Administrative Manual is 1,400 thru 1,499.
4.8 Consultants
Costs of professional and consultant services rendered by persons who are members of a particular profession or possess a special skill and who are not officers or employees of the university are allowable when reasonable in relation to the services rendered. There are many sponsors (mainly federal) that limit these costs. Costs for travel, per diem, clerical services, vacation, fringe benefits and supplies are exclusive of personal compensation and are allowable as appropriate.
A consultant payment can not be made to an employee of the university system. Instead, the individual must be compensated for services via applicable university personnel/payroll procedures. All consultant payments on sponsored projects must be in accordance with the board of regents procedures and the applicable sponsor regulations.
Contact GCO for details.
4.9 Hosting Expense
Hosting expenses are those expenses incurred pursuant to fund-raising, recruitment, public relations staff development employee/student relations or other bona fide university business activities. Reimbursement for host expenses is specifically intended to include only expenditures of a strictly business nature, not entertainment.
The term "hosting expenses" includes the following:
Hosting is not to be construed as a vehicle to pay expenses otherwise not allowed by state or the board of regents regulations. The hosting expense must be listed specifically in the budget and approved by the sponsor or the PI must have prior written approval from the sponsor.
4.10 Computers and Computing Services
Expenditures charged to a sponsored project for a computer must be verified and subject to audit. Normally, charges for the use of PC's on sponsored projects will not be allowed. The recovery of use allowance for university titled equipment is through the indirect cost allocation. Actual maintenance charges will be allowed only after certification that the equipment was being used on the project.
The university has a research computer, which is available for research and instructional activities. Contact the computing center, x6749 for details.
4.11 Specialized Service Facilities
The cost of services is any separately accounted for activity (highly complex or specialized facilities) of the university, which provides and charges for goods or services primarily to departments on campus. It will be charged directly to users, including sponsored projects based on actual use of the service and a schedule of rates that does not discriminate between federal and non-federal supported activities.
The charges are designed to recover not more than the aggregate cost of the services over a long-term period agreed to by the university and their cognizant audit agency. Contact the Controller's Office x4297 for details.
4.12 Direct Costs
Direct costs are costs that can be identified specifically with a particular sponsored project, relatively easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances must be treated consistently as either direct or indirect costs. Where the university treats a particular type of cost as a direct cost of sponsored agreements; all costs incurred for the same purpose in like circumstances shall be treated as direct costs of all activities of the university.
A particular cost is chargeable as a direct cost if it meets all of the following criteria:
A cost element is not chargeable as a direct cost if it is incurred or shifted (transferred):
4.13 Indirect Costs
Indirect costs are costs that are incurred for common or joint objectives and therefore, can not be identified readily and specifically with a particular sponsored project. The costs are classified within two broad categories:
Indirect costs are reimbursement for actual costs. It should be emphasized that indirect costs are not merely convenient accounting fictions; they are matters of fact. The assessment made against sponsors for indirect costs, therefore, is reimbursement to the university for costs actually incurred. It is not in any sense profit, bonus or a service fee.
Responsible sponsor representatives are fully aware that indirect costs are a sizeable portion of the total cost of supporting research. Sponsors judge proposals not by the indirect cost rate but by the professional standing of the faculty member, the merit of the proposed work and the pertinence of that work to their own goals.
The university can not afford to accept funds for non-teaching activities without recovering the total (direct and indirect) costs of the activities. When the university must pay these costs from their own funds, money must be diverted from other needs. The university is justified in occasionally accepting support that does not cover all the costs, because of the undeniable benefit of a large research project to its faculty and students.
Where the sponsor allows indirect costs, it is the policy of the university to request the maximum allowable amount. Where a solicited proposal specifies an indirect cost rate less than the maximum allowable amount or less than the rate currently accepted by the university, the PI must provide a statement of justification when submitting the proposal to OSPA. OSPA has the authority to accept extramural funding at less than the maximum allowable indirect cost rate and has the authority to refuse a sponsored project when full indirect costs are not recovered.
4.14 Cost Share and Matching
Cost share and matching is the portion of the total project cost, which the university is required to expend to meet the terms and conditions of certain projects. The sponsors will have their cost share requirements listed in the request for proposals (RFPs).
The term "Cost Share" is used when the agency encourages the university to share in the cost of the project.
The term "Matching" is used when the agency is required by statute to have the university share in the cost of the project.
All contributions, including cash and third party in-kind, shall be accepted as part of the university's cost sharing or matching when such contributions meet all of the following criteria:
The following may also apply:
The faculty member should carefully consider the amount of cost sharing or matching that is actually necessary as well as the difficulty involved in documenting it. Unfulfilled promises (or poor documentation) will result in a disallowance to the project when audited. The sponsor will reduce their support and require reimbursement if the university fails to provide all promised support.
Many sponsors are requiring the cost share to be reported when GCO submits invoices. Therefore, the amount of cost share and the expenditures reported must be in the same ratio as required in the award.
4.15 Indirect Cost Recovery Distribution
The following in the approved distribution of indirect cost recovery monies by GCO:
|
|
|
|
| College | 25.0% | 12.5% | |
| Cont Education | 12.5% | ||
| Office/President | 25.0% | 37.5% | |
| Research Stimulation | 25.0% | 12.5% | |
| State Approp. Funds | 50.0% | 50.0% | 50.0% |
Fund 1207 exists with separate accounts to reflect these distributions and any further allocations of the indirect cost recovery directed by each college.
The funds distributed are available for spending subject to the following limitations:
When distributions previously made are corrected, they are usually small and can be made by altering subsequent monthly distributions to the college. When projects are overspent or audit disallowances occur, the college is expected to cover this from another appropriate account. GCO will work with the college in resolving such a situation. However, if no mutually acceptable approach is found, GCO is instructed to divert the flow of funds to the college to cover such over-expenditures.
4.16 Cost Transfers
Occasionally it may be necessary to transfer costs involving a project. However, necessity and propriety must be examined when considering the need for a cost transfer. Cost transfers must be processed in a timely manner. Therefore, it is very important to reconcile the accounts to determine if there has been an error. Cost transfers that affect prior year state budgeted funds are not allowed. A general journal voucher may be utilized to request non-payroll transfers only. Payroll transfers must utilize the "Request for Change of Payroll Charge". A copy of the form General Journal Voucher and the form Payroll Document P/R 45 is included in Appendix 2.
GCO will review each transfer to determine its validity. An authorized individual for the project must sign the journal voucher. If the error has been detected in an untimely manner, the circumstances surrounding the delay in detection must be explained. An explanation which merely states that the transfer is requested "to correct error" or similar language will be considered incomplete. All incomplete or poorly documented transfers will be returned to the initiator for clarification or supplemental information.
Refer to clause 4.12 Direct Costs for further explanation of legitimate costs.
4.17 Budget Amendments and Rebudgeting
As work on a project proceeds, changes may be required in the project budget. All budget revisions must be made in accordance with the sponsor's and the university's guidelines and submitted to GCO. All necessary approvals must be obtained before project funds are expended.
Many sponsors permit considerable budgetary flexibility without prior approval if the scope of the project is not materially altered.
The following should be followed when the need for budget revisions has been determined:
Many sponsors require prior approval for rebudgeting if it is more than a certain percentage. Also sponsors have begun to consider more than 25 percent rebudgeting a change in the scope of work for the project and will need prior written approval. Normally the following categories of the budget are sensitive or restricted:
4.18 University Prior Approval System (UPAS)
The Department of Health and Human Services (DHHS), National Science Foundation (NSF) and the U.S. Department of Agriculture (USDA) have given the university authority to approve budget revisions for most categories of the budget.
UPAS ensures that the appropriate university officials provide necessary organizational reviews and approvals in advance of any action for which approvals are required by the project. These actions include the obligation or expenditure of funds where the governing cost principles either prescribe conditions or require approvals.
The Vice President for Research reviews any requests for program modification and the Manager of Grants and Contracts will review the requests for financial approval.
If a budget revision is necessary reference clause 4.17 for details.
4.19 Cost Overruns
If there is a cost overrun on a project, GCO will notify the PI. A copy of the form Overspent Sponsored Project CONT-GC-07 is included in Appendix 2. The PI will have a sufficient length of time (normally 30 days) to identify a non-sponsored alternate-funding source for the cost overrun.
If it becomes necessary, GCO will contact the dean of their unit and coordinate the use of indirect cost recovery funds to correct the problem. In all instances, the PI and the department chair will be kept apprised of the final disposition.
4.20 Cash Receipts
GCO has the responsibility for preparing and submitting all invoices for project expenditures to the sponsor. All sponsor funding must be deposited with the cashiers through GCO. GCO is responsible for the follow up on delinquent sponsor receivables. If a PI or departmental personnel erroneously receive a sponsor’s payment, the payment with information identifying the project should be transmitted to GCO immediately.
All sponsor checks must be payable to:
The Board of Regents
University of Nevada at Reno
4.21 Refund of Expenditures
A refund transaction is a repayment for an earlier charge. Refunds typically occur from vendors for returned materials or overpayment. Refunds can occur if there is an overpayment of salary to an employee. Also, refunds may occur in travel if part of the airline ticket was not used and refunded by the travel agency. Never allow the travel agency to issue a credit memo because the PI may use the credit memo on another project, which makes it an unallowable expense.
When a check is received by the department that represents a refund against a previous expense to a project, it should be forwarded to GCO. The check, accompanied with the necessary information to identify the original transaction, will be credited to the proper account, with the original object code. The transaction will appear on the next scheduled status report and will be displayed as a credit in the object code of the original expenditure.
Never deposit the check because it will overstate the funding received and the money can not be spent on other legitimate expenses.
4.22 Personnel Activity Report (PAR)
It is a requirement to certify that all salary charged does not exceed 100% of the employee’s time. Therefore, all university employees under professional, letter of appointment, graduate assistant, postdoctoral contracts, classified and technical employees devoting time and effort, including cost share or matching, to sponsored projects inclusive of Agricultural Extension Service and Agricultural Experiment Station must report their effort. The PAR will reflect 100 percent effort during the applicable period. The form PAR CONT-A/S001 is included in Appendix 2.
The form must be completed monthly by the 15th of the following month for classified and technical employees and each academic term of appointment period within 30 days of the end of each academic term or period for professional (academic and administrative) and graduate employees. This is an after-the-fact certification. It is the responsibility of the department chair or director of the unit to insure that PARs are completed for each employee who meets the requirements.
The PAR will be signed (original signature only) by the employee or supervisor having first-hand knowledge of all work performed by the employee. The distribution of activity represents a reasonable estimate of the work performed during the stated period.
For questions regarding completion of the form please call Accounting Services, x4160.
5 PROPERTY MANAGEMENT
5.1 Equipment
The definition of equipment is an article of nonexpendable tangible personal property having a useful life of more than one year and an acquisition cost of $2,000 or more per unit.
5.2 Fabricated Equipment
If property is fabricated from individual component parts, each component must itself be classified as equipment if it meets the definition.
5.3 Property Acquisition and Control
The university is directly responsible and accountable for all property purchased or acquired on a sponsored project, in accordance with the policies and procedures of the sponsor and the State of Nevada.
The PI and the chair of the custodial/sponsoring department have the primary responsibility of the care, custody, maintenance, records and control of all property acquired under the terms of the project. They must maintain up-to-date departmental records and initiate such forms as are necessary to fully inform the Purchasing Department (equipment management section) as to all provisions of the contract document.
All inventorial property will be identified, marked with the property inventory number and recorded promptly upon receipt. Title to purchased property will vest with the university unless otherwise stated.
The following must be accomplished before purchase of equipment is allowed:
The Purchasing Office will only process the requests to purchase equipment when the criteria stated above are met. There are additional criteria concerning the technical aspect of the equipment to consider as well.
5.4 Project Closing
When the project has ended all equipment must be inventoried and disposed of in accordance with the sponsor’s policies. The university will request disposition of equipment. Title to equipment may remain with the sponsor or they may transfer title to the university. The university will adhere to the sponsor's policies as a condition to receiving title.
6 PROGRAM INCOME
Program income is gross income earned by the university that is directly generated by a supported activity or earned as a result of the project. Program income includes, but is not limited to:
Interest earned on advances of sponsor funds is not program income. Program income does not include the receipt of principal on loans, rebates, credits, discounts, etc., or interest earned on any of them.
The program income will be used in one of the following ways:
All program income will be separately budgeted and accounted for. The PI will request a separate account be set up for the revenue and expenses. A copy of the form CONT-GC-16 is included in Appendix 2. The program income account will be subject to the same conditions of the sponsor as that of the account that generated the program income.
7 CLOSE OUT OF SPONSORED PROJECTS
7.1 Reconcile Account
The sponsor's guidelines and report submission dates will be adhered to in closing out a project. The PI is responsible for submitting, in a timely manner, all final technical reports and other nonfinancial statements or reports required by the sponsor.
Sponsoring agencies do not normally send expiration notifications to either the PI or the university. GCO will notify the PI of the termination 30 to 45 days prior to the ending date of the project. A copy of the Sponsored Project Termination form CONT-GC-06 is included in Appendix 2. The termination notice will remind the PI to:
It is the responsibility of each PI to submit the required copies of the final technical report, by the date specified in the award document, to the sponsor. Failure to comply may jeopardize current and future funding. If the project is to continue with or without additional funds, the PI will forward the necessary paperwork to OSPA. The final financial report will be submitted by GCO.
GCO will review revenue and expenses of the project. GCO will promptly refund any balances of cash that is not authorized to be retained. Closing the account does not affect:
7.2 Supply Inventory
Title to supplies and other expendable property shall vest with the university upon acquisition. For a federal project, if there is a residual inventory of unused supplies exceeding $5,000 in total aggregate value upon termination or completion of the project and the supplies are not needed for another federal project, the university shall retain the supplies for use on a non-federal sponsored activity or sell them, but shall, in either case, compensate the Federal Government for its share. The amount of compensation shall be computed in the same manner as for equipment.
The university shall not use supplies acquired with federal funds to provide services to non-federal outside organizations for a fee that is less than private companies charge for equivalent services, unless specifically authorized by federal statute as long as the Federal Government retains an interest in the supplies.
GCO will notify the PI when there was more than $5,000 of supplies purchased during the period of the project. The PI must certify one of the following:
The PI will review, sign the form and return it to GCO. A copy of form CONT-GC-05 is included in Appendix 2. This document will be retained in the file and be available for audit purposes.
7.3 Cost Sharing
The total amount of the cost sharing or matching requirements will be documented by the close of the project. The final report submitted to the sponsor will contain both the project expenditures and the cost share expenditures. The project and cost share expenditures may be audited at a later date. If expenditures are disallowed, the PI and/or the department are responsible for reimbursement to the sponsor.
7.4 Fixed Price Award
Closing a fixed price award will include the following:
7.5 Audit Disallowances
All restricted sponsored project funds will be subject to audit. The auditor shall determine whether:
Material findings of noncompliance will include:
Resolution of audit findings will be the responsibility of the university and the sponsor. Corrective action should proceed as rapidly as possible.
7.6 Termination and Enforcement
Awards may be terminated by the sponsor in whole or in part only if:
Awards may be terminated by the university in whole or in part only if:
If the university materially fails to comply with the terms and conditions of an award, the sponsor may take the following actions, as appropriate in the circumstances:
In taking an enforcement action, the sponsor shall provide the university an opportunity for hearing, appeal, or other administrative proceeding to which the university is entitled under any statute or regulation applicable to the action involved.
Costs of the university resulting from obligations incurred by the university during a suspension or after termination of an award are not allowable unless the sponsor expressly authorizes them in the notice of suspension or termination or subsequently. Other university costs during suspension or after termination which are necessary and not reasonably avoidable are allowable if:
7.7 Assurances
The university must certify that work of the project will be performed in accordance with all assurances. Examples of assurances are:
7.8 Retention and Storage of Records
Financial records, supporting documents, statistical records and all other records pertinent to an award shall be retained for a period of at least three (3) years from the date of submission of the final expenditure report or, for awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report. The only exceptions are the following:
The following applies to indirect cost proposals, cost allocation plans and any similar accounting computations of the rate at which a particular group of costs is chargeable (such as computer usage chargeback rates or composite fringe benefit rates:
8 APPENDIX
8.1 Organization Charts
Chart 1 reflects the organizational structure of the Office of Sponsored Projects Administration.
Chart 2 reflects the organizational structure of the Grants and Contracts Office.
8.2 Forms
The forms are included for your reference. Please call the designated office for copies and instructions:
Accounting Services - x4164
Grants and Contracts - x4312
Office of Sponsored Project Admin -x4040
9 GLOSSARY
This glossary defines some of the most frequently used terms in the administration of sponsored projects.
Account Number - The financial record established by the Grants and Contracts Office to provide current information on obligations, revenue and disbursements of a project. Also referred to as budget number or department/project number.
Agency - That organization to which application is made for support of a sponsored project.
Applied Research - The systematic, intensive study directed toward the practical application of knowledge and problem solving.
Authorized Signature - The chancellor of the university system or designee are the only authorized signatories in executing an agreement for a sponsored project. Once the account is established the PI is the authorized signer and may authorize other persons to spend funds on their project.
Basic Research - The systematic, intensive study, the primary aim of which is a fuller knowledge or understanding of the subject under study rather than a practical application.
Budget Period - Inclusive dates of the sponsored project which are specified by the agency; there will be no expenditures before or after the dates without written prior approval from the agency.
Consultant Services - Payments to individuals for professional services who are not university employees.
Contract - A document of agreement between a sponsor and the university by which the sponsor agrees to pay costs incurred for specific services or research goals.
Cooperative Agreement - A financial assistance agreement used when substantial sponsor involvement is anticipated with the university during performance of the project.
Cost Sharing - The portion of project costs which is not borne by the sponsor. The term cost sharing is used when the sponsor encourages the university to participate in the project. The term matching is used when the sponsor is required by statute to have the university participate in the project.
Direct Costs - Those costs that can be identified specifically with a particular sponsored project relatively easily with a high degree of accuracy.
Effort - The total activity or work for which an employee is compensated by the university.
Encumbrances - Unliquidated commitments or obligations against the account; those financial commitments made against the account which have not yet been paid.
Equipment - Means an article of nonexpendable tangible personal property having a useful life of more than one (1) year, and an acquisition cost of $2,000 or more per unit. Included in the net invoice price is the cost to make it usable for the purpose for which it was acquired.
Expiration Date - The date signifying the end of the current budget period, as indicated on the award document, after which the university does not have authority to obligate project funds.
Fabricated Equipment - Equipment fabricated from component parts, which for each unit has a useful life of more than one (1) year and the net acquisition cost is $2,000 or more.
Fixed Price Award - This is an agreement in which the university guarantees to deliver a product or perform the work within the specified period at a fixed price agreed upon in advance, and payable regardless of actual costs.
Fringe Benefits - Include expenditures and contributions made by the university on behalf of the employees.
General Purpose Equipment - Means equipment, the use of which is not limited only to research, medical, scientific or other technical activities. Examples of this type of equipment include office equipment and furnishings, air conditioning equipment, reproduction and printing equipment, motor vehicles and automatic data processing equipment.
Grant - A document of agreement between the sponsor and the university to carry out approved activities. A grant is used whenever the sponsor anticipates no substantial programmatic involvement with the university during the performance of the activities. Examples of grants are; continuing, consortium, demonstration, formula, project, capitation, conference, construction, consultation and education, continuing education, facilities assistance, fellowship, financial distress, planning and research.
Hosting Expense - Expenses that are incurred for business, not entertainment. The sponsor must approve all hosting expenses.
Indirect Costs - Those costs that are incurred for common or joint objectives and therefore can not be identified readily and specifically with a particular project.
Indirect Cost Rate - The ratio, expressed as a percentage, of the total indirect cost to the direct cost base (modified total direct costs).
In-kind Contributions - The value of noncash contributions, which may be in the form of property, goods or services directly benefiting and specifically identifiable to the project.
Line Item Budget - A budget that lists the cost of all personnel participating in a project as well as the cost for all other budgeted items.
Notice of Award - The legally binding document that notifies the university that a proposal or grant application has been made.
Organized Research - Means all research and development activities of the university that are separately budgeted and accounted for. It also includes activities involving the training of individuals in research techniques (commonly called research training) where such activities utilize the same facilities as other research and development activities.
Principal Investigator - The designation of a faculty member who is given responsibility for the project.
Program Income - Gross income earned by the university that is directly generated by a supported activity or earned as a result of the project.
Special Purpose Equipment - Means equipment which is used only for research, medical, scientific or other technical activities.
Subagreement - A collaborative effort with another institution when their expertise is needed to fulfill the terms of the project. Also referred to as subcontract or subgrant.
Unencumbered Balance - The monies in the account not yet spent or committed.
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