Sponsored Programs (SP) in collaboration with the Principal Investigator (PI) is responsible for administering all sponsored projects awarded to the University. This includes monitoring budget transactions, verifying and enforcing sponsor terms and conditions, processing administrative reports, preparing and overseeing subcontracts, and implementing changes mandated by both Federal and private agencies.
The Controller’s office is responsible for monitoring expenditures to ensure compliance with University Policies and Procedures and sponsor requirements. The Controller’s office is also responsible for the distribution and interpretation of financial accounting information such as monthly budget reports.
When a PI agrees to implement a sponsored award or contract, he/she assumes legal, managerial, and ethical obligations. Not only must a PI have the technical expertise to produce and deliver the products or services outlined in the grant, he/she must also possess managerial skills to ensure the program’s objectives are achieved in an efficient and cost-effective manner. Even a well-executed project that meets its objectives will not be considered favorably by the sponsor if there are reporting and budget problems. Therefore, it is highly recommended that a PI become familiar with fundamental managerial concepts, since this can be a deciding factor in a program’s failure or success.
Quarterly SP will meet with PIs for specific program/agency compliance training, budget review, and project update meetings.
The Controller’s office provides the PI with information as needed to effectively manage his/her award and monitors the financial activity on contracts and grants to ensure compliance with University policies and procedures and sponsor requirements. The Controller’s office coordinates all audits within the contracts and grants area performed by the University’s independent auditors, Federal agencies and other sponsoring agencies.
Although the Controller’s office prepares financial reports for each project, it is the responsibility of the PI to ensure that all expenditures are allowable. Federal grant expenditures must be allowable as defined in OMB Circular 2 CFR 200 and the University Operations Manual. The University’s grant accountants are available to answer any questions a PI may have regarding the allowability of costs
To establish an account, SP will provide the Controller’s office with the award letter from the sponsor, a copy of the proposal transmittal, and the approved proposal budget (revised if necessary). The account is set-up in accordance with the approved budget and the sponsor’s specified terms and conditions. The Controller’s office then sends an Account Number Request/Authorization form to the PI for signatures. This form provides the PI with an account number. SP then meets with the PI to review the specified terms, conditions, and reporting requirements, and provides the PI with a fully-executed copy of the award agreement.
SP will schedule quarterly meetings to offer just-in-time training for the PI to fully understand the administrative requirements for executing the funded program. PIs are required to attend quarterly meetings to complete the “Uniform Administrative Requirement for Grants and Agreements Check List.” It is the responsibility of the PI to ensure that grant funds are expended in accordance with the award agreement.
The PI is required to submit to the Controller’s office documentation supporting any deviations from the approved budget and/or exceptions/changes to the terms and conditions. It is the responsibility of SP to contact the funding agency relative to the PI’s request and clarify any questions raised. The PI should not spend based on the revised budget until written approval is received from the sponsor (if required by the grant).
PIs or program directors can monitor their grant accounts by accessing mySVSU portal. The system tracks monthly and year-to-date expenditures for each grant account. Using the system on a consistent basis helps the PI fulfill his/her role as the primary grant manager and allows him/her to contact Sponsored Programs or grant accountant to correct any inconsistencies immediately.
If indicated in the grant budget, one of the first steps in implementing a sponsored project will be the hiring of project personnel. The SVSU Department of Human Resources (HR) will help with this process. All positions funded by grants and contracts require that a full affirmative action search be conducted. However, recruitment efforts may vary depending on the type and level of the position. Recruitment procedures, checklists and forms are listed at www.svsu.edu/hr under Policies.
HR will prepare contracts of employment in cooperation with the PI. Yearly performance reviews are required. Personnel forms such as the HR Action Form may need to be updated annually or semi-annually, depending on the grant’s end date.
If you are hiring a student worker for a grant funded position, you first need to post the job description with SVSU’s Office of Career Services, then interview at least three of the applicants. A student job description template will be provided at the initial meeting.
Contractual Services Procurement Policy
Consultants provide technical expertise for a limited duration necessary for the conduct of the sponsored project. Consultants are temporary arrangements with external companies or individuals. The following are example situations when SVSU might need a consultant:
Procedures to be followed when procuring a consultant
The project director will work with Sponsored Programs to make available the consultant’s scope of work, time period for the work, qualifications required, and any technical requirements. A range of acceptable characteristics and/or minimum of acceptable standards must be provided. Competitive procurements must not contain language which restricts competition; efforts should be taken to utilize small businesses, women owned firms, and/or minority owned firms. Project Directors will make the position available internally to SVSU employees, as appropriate, and externally to qualified consultants.
Possible Places to Post for Consultants
Hiring Process. Before deciding who to hire, at minimum three candidates must be considered/ interviewed by the project director. Check consultant's background. Consideration should be given to factors including integrity of the consultant, record of past performance, financial/technical resources, and accessibility to other necessary resources. Consultants vary widely in their skills and abilities. Some are at the top of their field, while others have more recently jumped on the consulting bandwagon. Due diligence includes checking references.
Procurement purchases in excess of the small purchase threshold (2CFR 200) should include a basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost/price.
Sponsored Programs will check for debarment and suspension on the General Service Administration’s list of Parties Excluded from Federal Procurement in compliance with 2CFR 200.
Procedures to be followed when hiring a consultant
Sponsored Programs will provide two templates (consultant contract and/or consultant memo) to use when hiring consultants which include scope of work description, insurance, confidentiality clauses, and termination clauses.
Procedures to be followed when paying an individual for independent/consultant service
Controller’s office will review whether the individual is to be paid as a consultant or as an employee per University Policies. The most important criterion is that the nature of the work performed is unique, that is, not offered at SVSU and not performed for a sustained period of time.
The IRS uses a 20–Factor Analysis to determine whether a worker is an employee or independent consultant. This Analysis is used by SVSU’s Controller’s office to make the final determination between consultant and employee. See IRS Analysis in Principal Investigator Implementation section under Project Management.
If it is decided that the individual is a consultant, the following documentation is required:
This documentation is necessary to provide a record for the IRS, showing that the individual qualifies as a consultant and to support the payment of the individual as a consultant using sponsored project funds. Each consultant situation is reviewed individually. In some cases, additional documentation may be required. If you have any questions regarding the procedures outlined above, please contact Sponsored Programs or Controller’s office.
In making the determination of whether a subrecipient or vendor relationship exists, the substance of the relationship is more important that the form of the agreement. It is not expected that all of the characteristics will be present and sound judgment should be used in determining whether an entity is a subrecipient or a vendor.
Subrecipient relationship exists when a third party:
Vendor relationship exits when a third party:
Subcontracts/Subagreements that were not included in the proposal often require the sponsor’s approval prior to executing a formal agreement and commencing work.
SP, in coordination with the PI, is responsible for preparing and overseeing subcontracts as approved in the sponsored project award and issued by the University to other organizations. In general, the subcontractor is subject to the same terms and conditions of the award, as is the University. Therefore, the subcontract agreement prepared by SP contains specific terms and conditions, an approved budget, and a statement of work. The subcontract is reviewed and approved by the PI.
To be binding, the subcontract must be signed by the authorized official of the University and the subcontractor. When the agreement is fully-executed, payment is made to the subcontractor per submission of an invoice, signed by the PI, by the Controller’s office. Extensions and changes to the subcontracts are made by SP and the Controller’s office based on the approval of the primary sponsor. The choice of a subcontractor must be documented with regard to the subcontractor’s qualifications to perform the work and the project’s need for such services. Competitive bids may be required; please consult with the Controller’s office to see requirement.
When to use a subagreement…
Subagreements are used to convey grant (financial assistance) and contract (procurements) funding received by SVSU from federal, state, industry, and private sources. Grants and contracts received by principal investigators and awarded to SVSU to conduct sponsored research may include components of work to be performed by collaborating investigators at separate institutions. When this occurs, a third-party sponsored research subagreement is required and will include: a) an executed subagreement between the parties, and b) a purchase order issued by the University system to the subrecipient.
SVSU is responsible to evaluate each subrecipient's risk of non-compliance with federal statues, regulations, and the terms and conditions of the subaward. SVSU will consider during the evaluation: 1) the subrecipient's prior experience with the same or similar subawards; 2) the results of previous audits including Single Audit requirements, 3) whether subrecipient has new personnel or new or substantially changed systems; and 4) the extent and results of federal awarding agency monitoring. SVSU will check the federal audit clearinghouse to see if the potential subrecipient has filed audits as required.
What sponsored research administration provides…
This guidance ensures the appropriate administration of sponsored research subagreements at Saginaw Valley State University to a) ensure consistency between policy and practice; b) articulate areas of responsibility for Sponsored Programs (SP), the Controller’s office (department responsible for sponsored research financial management), principal investigators and divisions; and c) to identify monitoring and audit requirements for subrecipients.
Where execution of a subagreement is required or advisable, SP will produce, negotiate, and execute a cost reimbursable or deliverable-based subagreement that ensures the technical requirements of the prime agreement are met. SP will coordinate additional reviews with appropriate units when the subagreement contains non-standard language that may conflict with SVSU or federal regulations. Subagreement templates will be reviewed by SVSU’s general counsel to ensure that the terms and conditions are consistent with applicable laws and regulations. The general counsel will approve or modify subagreement templates to legally acceptable language, coordinating such changes with SP.
SP will secure the appropriate signatures of the subrecipient and will execute or cause to be executed the subagreement on behalf of SVSU, under authority delegated by the SVSU President. SP will also secure the approval of the principal investigator for the subagreement document and conduct the Subrecipient Financial Questionnaire (20KB) prior to the execution of a new subaward or when audit findings are related to Federal awards. When appropriate, funding agency terms and conditions regarding rebudgeting will apply to the subagreement. SP will transmit one copy of a fully executed original to the subrecipient. One copy of the subagreement will be sent to the principal investigator and one copy to the Controller’s office.
Subrecipient Monitoring Responsibilities
The administration of subawards is a shared responsibility between the Principal Investigator, Sponsored Programs, and Controller’s Office. Responsibilities are divided as follows:
Principal Investigator - is responsible for the overall scientific and technical progress of the prime award and scientific and technical progress of the subrecipient. The Principal Investigator is responsible for monitoring the activities of the subrecipient to help ensure the Federal funds are being used for their authorized purpose and that performance goals are being achieved. The Principal Investigator should review and approve of the scope of work, budget, and progress reports submitted by the subrecipient. The Principal Investigator should also address any problems that the subrecipient may have in carrying out the project.
Sponsored Programs - will develop and obtain a signed agreement with the subrecipient. The subrecipient agreement should contain the following items: CFDA title and number, Award name, Name of Federal agency, Subaward amount, Period of performance, Compliance requirements. SP will help to ensure that subrecipients have been audited in compliance with OMB 2 CFR 200 and will work with the Principal Investigator and Controller’s Office to verify that Quarterly Narrative Reports, Financial Reports, and Final Performance Reports are submitted in a timely fashion, when required. SP will also issue any amendments or modifications of the subaward and approve of significant changes to the subaward (for example, change if scope of work, change in personnel, etc.).
Controller’s Office - will review and approve the subrecipient’s invoices, pay the invoices, and monitor the financial progress of the subaward. The Controller’s Office will help to ensure that final invoices are received within 60 days of the end date of the subaward and that all subawards have been closed out between 45 and 60 days following the expiration of the subaward. The Controller’s Office will perform on-site visits when circumstances warrant, on the request of the Principal Investigator or Controller.
Purchase Requisitions
SP, in concert with the principal investigator, will initiate a purchase requisition to the Purchasing office with the subagreement document attached to and made a part of the purchase order to ensure that funds are available in the subagreement and that funds are properly encumbered and dedicated to the purpose of this procurement. SVSU must maintain the rationale for the method of procurement, selection of the contract type, contractor selection or rejection, and the basis for the contract price.
The principal investigator will be responsible for monitoring and ensuring the technical performance of the subrecipient and will certify performance prior to the payment of any invoices by the Controller’s office. SP will retain the supporting documentation for the subrecipient’s performance.
SP will coordinate the acceptability of payment and billing terms and procedures with the Controller’s office. Payment and billing terms will generally follow the payment and billing terms of the prime sponsor. Subrecipient cost and pricing documentation will be maintained by SP and approved by the principal investigator. The principal investigator will examine the invoice and may request additional documentation to determine that charges are consistent with work performed and are in accordance with the prime agreement terms and conditions.
Invoices for payment to subrecipients will be submitted by the principal investigator to SP for compliance review and then SP will process and forward required documentation to the Controller’s office at SVSU referencing the purchase order and subagreement. The subrecipient’s services must be received prior to payment processing. The invoice will be signed by a subrecipient employee who is knowledgeable and authorized to do so attesting to the accuracy of the invoice and that the deliverables or expenditures for reimbursement in accordance with the subagreement and were made solely for the performance of the subagreement.
Documentation required for invoicing
Subrecipients with cost reimbursable subagreements must submit an itemized invoice using the same cost categories that appear in the approved and executed subagreement budget and maintain detailed documentation in support of the expenditures and deliverables shown in the invoice.
SP will request from those subrecipients, covered under 2 CFR 200, a copy of the most recent audit or the most recent independent audit for review. The Controller’s office will review the audit reports and take appropriate follow-up steps as required based on any relevant audit findings.
Deliverable-based contracts do not require cost documentation.
Travel costs are the expenses for transportation, lodging, meals, and related items incurred by employees who are traveling on official business for the University as stated in the approved budget. It is important to first understand SVSU’s travel policy, which can be accessed at http://www.svsu.edu/operationsmanual. If the project’s Sponsor requires compliance with regulations as outlined in OMB Circular 2 CFR 200, another set of rules also applies. It is necessary that the PI become familiar with the policies that govern their award to avoid unallowable costs. (Also see program announcement for additional restrictions and guidance.) Reimbursements require itemized receipts.
What if the conference is canceled and I have e-credits? Flight charges may remain on the original account until the travel occurs. The travelers are encouraged to use the e-credit for the same project within the airline deadline to use e-credits. If the traveler is unable to charge the original grant project, internal cost transfer paperwork is done to transfer to the correct account. Reason(s) stated for using this method: reduction of journal paperwork upfront with emphasis on documenting communication.
For costs that were non-refundable and non-cancelable, PIs are allowed to still charge the grant but the PI has to provide documentation from the vendor that they would not refund or cancel the expense. If the e-credit is used for personal use, the individual would have to reimburse the university if the university paid for the original ticket.
When purchasing any individual items (goods or services) with a unit cost or total cost of a group of items of $1,000 or more, the PI needs to provide a written documentation to the Purchasing Department and the Controller’s office. Purchasing documentation will help to ensure that the acquisition of goods and services are done in a competitive, fair, and timely manner. Records will include, but aren’t limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.
All competitive procurement is the responsibility of the Purchasing Department per University policy. See Operations Manual for further guidance. Per June 20, 2018 M-18-18 Memorandum for Chief Financial Officers and Heads of Small Executive Agencies, for FY2018 OMB is granting an exception allowing federal award recipients to use the higher threshold of $10,000 for micro-purchases and $250,000 for simplified acquisitions in advance of revisions to the FAR at 48 C.F.R. Subpart 2.1 and the Uniform Guidance.
The documentation must be received and considered by Purchasing prior to commitment of an order. The Purchasing Department is responsible for managing the bidding process for most of the goods and services required by University departments. Within its scope of operation, Purchasing handles the qualification of potential bidders, the solicitation and analysis of bids, and the awarding of business to consultants. It is important, therefore, that each PI communicate their needs and plans for major purchases to the Purchasing Department as early as possible so there will be reasonable time to accomplish the bidding procedure.
According to University policy, equipment purchased with sponsored project funds is defined as having a unit cost of $5,000 or more and a useful life of greater than one year. Equipment to be purchased with Federal funds must be approved by the sponsor in advance and listed in the proposal. If you wish to purchase equipment not listed in the proposal, you must receive prior approval through SP from the funding agency. The purchase of general-purpose equipment (for example, office equipment and furnishings, reproduction and printing equipment, or computers) is allowable only if the equipment is primarily used to carry out project activities and the purchase has been approved by the sponsor.
Note: All supplies and equipment purchased for sponsored projects remain the property of Saginaw Valley State University at the end of the grant period.
University policy guidelines require that all non-expendable property having an acquisition cost of $5,000 or more and having a useful life greater than one year is subject to property control. Property control includes the maintenance of property records, the tagging of equipment items, and periodic physical inventories (at least every two years).
A representative from the Controller’s office will coordinate the tagging and inventory of all equipment items with the assistance of the PI. The PI is held responsible for the location of the equipment as well as the maintenance. The information on record, which is necessary for the maintenance of the property inventory file, is as follows:
|
|
|
|
|
|
|
|
|
It is the responsibility of the PI to ensure that purchases are allowable within the grant guidelines. For Federal grant projects, items which are not allowed (2 CFR 200) include, but are not limited to: entertainment, alcoholic beverages, promotional items, advertising, club dues, and legal fees. As the primary grant manager, it is recommended that the PI become familiar with the cost principles. Questions concerning allowable costs should be directed to Sponsored Programs.
The University’s grant accountants are available to meet with a project’s PI, department secretary, or administrative assistant to review how to fill out and submit the appropriate forms for the payment of an expenditure and answer any budget-related questions. No expenditure payment will be approved prior to the receipt of the official award notification of funding by the sponsor.
Cost transfers are occasionally needed to correct errors in original charges. There are instances, however, where cost transfers can be avoided simply by reviewing the original charge to see that it is set up correctly. Directly charging the appropriate program (account) initially results in fewer cost transfer requests. This policy ensures timeliness in transferring costs and keeps the University compliant in the event of an audit.
Frequent cost transfers may indicate the need for enhanced internal controls and/or accounting system improvements. Cost transfers are generally more scrutinized and increase the risk of an audit. Cost transfers follow University and sponsor policies. For example, expenses must be all of the following:
Cost transfers should be completed within 90 days of when the expense originally appears in the transaction detail (Datatel). Transfers requested after this time period will require additional justification and supporting documentation explaining how the error occurred.
Cost transfers must be certified to approve the new charge; the PI is the fiduciary of the project and its expenditures. Additional approval will be necessary for those transfers completed more than 90 days after the expense appears in the transaction detail (Datatel).
Possible Reasons for a Cost Transfer
What Should Your Justification Include?
Complete a cost transfer form to justify/document why the transfer is necessary. The justification should be understood by anyone reviewing it and should answer the following questions:
Examples of Acceptable Cost Transfer Explanations
Examples of Unallowed Cost Transfer Justifications
Who Pays for Disallowed Cost Transfers
Cost transfers that are disallowed due to timing or insufficient justification/ documentation will be funded by the department with which the grant is affiliated per University Policy noted on the Account Number Request/Authorization Form. The department will also fund disallowed cost transfers discovered during grant audits.
FCOI disclosure is basically anyone who could reasonably be perceived to have an influence on the collection, interpretation, or outcome/reporting of the research results. Key personnel are persons who contribute significantly to the science, so FCOI disclosure is not limited to key personnel. Any one on the project must (a) complete CITI's online Conflict of Interest course and then (b) complete a short questionnaire about whether or not they have an FCOI with this particular project.
Financial reports (including final financial close-out reports) which are required by the sponsor are the responsibility of the Controller’s office. The objective is to ensure that the financial reports submitted by SVSU to sponsors are presented fairly, timely, and contain complete and reliable information. Financial reports are generally due within 90 calendar days of the end of each budget period, but may vary according to specific program guidelines. It is the responsibility of the PI to ensure that all transactions for the budget period are completed and expensed against the sponsored project account by the end of each budget period. Any balance not obligated on a sponsored program will be returned to the sponsor unless the sponsor has authorized (in writing) that the unexpended funds may be retained by the University or carried over for use in continuing years of the project. All reports containing any financial information must be reviewed and submitted by the Controller’s office.
Faculty, staff and student effort is needed to achieve a grant’s scope of work. If effort is charged to the grant account or reported as cost share, it must be recorded in a timely manner. The Project Time Log (SP website) and the In-Kind database (https://webtech.svsu.edu/inkind/) are two methods available to salaried employees to track grant effort. To access the database online, you must be added as a user by SP personnel. SP recommends that effort be logged daily and certified monthly by the person performing the effort. Controller’s office will verify grant effort three times per year by the person performing the effort and the PI. PI effort is verified by the PI’s supervisor or dean three times per year. At minimum SVSU will annually certify grant funded positions charged 100% to the project to verify maintenance of effort/supplanting restrictions are being met. When a faculty member is paid during Spring/Summer term, he/she will need to log hours to support rate of pay is consistent with base salary.
Federal awards are subject to annual audits by the University’s independent auditors as dictated by the Office of Management and Budget Circular 2 CFR 200. This audit is performed to ensure that the University is managing its Federal awards in compliance with applicable laws and regulations. The audit includes tests of internal control systems affecting all Federal awards, as well as tests of individual transactions. The results of the audits are reported to the Federal government (Department of Navy, SVSU’s cognizant agency).
In addition to the annual audit, the University may be subject to audits of individual awards. These audits are typically conducted by the sponsoring agency. The PI will be notified of this upcoming visit and will receive support of the Controller’s office and SP in preparation for the visit. Any resulting report will be filed with the Controller’s office and SP.