Policy Name: Post-Award
Financial Management of Sponsored Projects
Maintenance: Office of Government; Grants and Alumni; Financial Services
As a recipient of federal grants and other
sponsored projects, Onondaga Community College is required to ensure:
- Internal controls are in place so that grant funds
are used solely for authorized purposes and consistent with applicable
- Project-based (“accumulated”) accounting records
are maintained with appropriate back up documentation;
- Principal Investigators (PIs) and Project Directors
(PDs) actively monitor and authorize uses of sponsored funds, including the
work of sub-awardees, and document these uses in relation to project objectives
for review by the funding agency;
- Time and effort reporting is consistently, accurately,
and timely documented by the individual working on a grant-funded project and
verified by the PI or the PD;
- Potential conflicts of interest are disclosed and
resolved or mitigated.
PIs and PDs, with support from Financial Services
and the Office of Government, Grants, and Alumni, are responsible to oversee
the finances of specific sponsored project(s); ensure implementation of College procedures
related to financial management, human resources, procurement, contract
accounting, information technology, and grants administration; authorize and
direct financial transactions of the sponsored activity; monitor and report on
the financial status of each sponsored project in relation to the sponsored project’s
stated plan or objectives; and, ensure timely preparation of required
This Policy complies with federal regulations
governing the uniform administrative management of federal sponsored
projects. To achieve consistency in post-award
grants management, these principles are applied to all externally sponsored
projects, regardless of the source of funds.
of the Policy
College faculty, staff, and all individuals and
organizations funded through a grant award, including sub-awardees, are subject
to this policy.
Anastasia L. Urtz, Vice President,
College-Affiliated Enterprises & Asset
Management and Compliance Officer
Mark Manning, Chief Financial Officer
A direct cost
is reasonable, allocable, and allowable and can be identified specifically with
a particular sponsored project.
- An indirect
cost is incurred by the institution for its general facilities and
administrative operations and cannot be identified specifically with a
particular sponsored project.
- A cost is reasonable
if the nature of the goods or services obtained on behalf of the sponsored
project and the amount spent for those goods or services reflect the action
that a prudent person would have taken under similar circumstances to
accomplish the project’s objectives.
- A cost is allocable
if it is incurred solely to benefit the sponsored project or to benefit both
the sponsored project and the work of the institution. If the cost benefits solely the sponsored
project, it may be assigned fully to the project. If the cost benefits both the sponsored
project and other objectives of the institution, then the cost generally may be
assigned to the sponsored project in proportion to the benefit to be
gained by the project.
- A cost is allowable
if it is reasonable, allocable, consistent with generally accepted accounting
principles appropriate to the circumstances, and not prohibited by regulations
or the terms of a specific sponsored agreement.
- Unallowable costs may
not be included as a direct cost of a sponsored project nor calculated as part
of indirect costs, unless specifically provided for in the sponsored award
agreement or negotiated directly and confirmed in writing from the awarding
agency. Unallowable costs generally
activities and alumni relations
and convocation ceremonies
or contribution to financial reserves
- Entertainment: amusement, diversion, social activities and
associated costs, such as tickets to events, meals, alcoholic beverages,
lodging, rentals, transportation, or gratuities
raising activities or materials
expenses, including memberships in social, dining or country clubs, and good or
services obtained for personal use
management, bad debt losses, internal interest expense, fines and penalties
relations unrelated to the performance of the sponsored project
- Student activities, such as student clubs or
- Compensation of personnel in excess of federal
A conflict of
interest exists when a PI’s or PD’s financial interests or those of their
immediate family members may be affected by the externally funded activity.
outset of a new sponsored project or upon a succession in PI or PD, the PI and
PD will participate in orientation with Financial Services, the Office of Management
Services, and the Office of Government, Grants, and Alumni to review applicable
procedures, reporting obligations, forms, and timelines. PDs managing federal
grants will complete annual training on federal grant management and compliance.
- The PI
and PD will complete a Conflict of Interest Disclosure Form and submit to the
Office of Government, Grants, and Alumni within thirty (30) days of
commencement of a new award year and each year thereafter for multi-year,
sponsored projects. In addition, the PI and PD will notify the Office of Government,
Grants and Alumni promptly upon the occurrence of any changes that affect an
earlier submitted disclosure. If a conflict of interest is disclosed, the Vice
President, College-Affiliated Enterprises & Asset Management and College
Compliance Officer will be advised and will determine, in collaboration with
the involved parties, how the conflict of interest will be resolved or
mitigated. If resolution cannot be
reached collaboratively, the College President will determine the appropriate
employees who have committed a percentage of their time to support a
federally-sponsored project must complete a time and effort report to certify
the work performed. This requirement applies to employees whose salary is paid
through the grant, as well as employees paid through the College who are
contributing time as a cost-share or in-kind match. In addition, the PI and PD will assure that
personnel costs charged to a project are consistent with the proportionate
benefit received by the project.
- Employees who dedicate 100 percent of their time to
one federally-sponsored project must complete a form certifying that 100 percent
of their effort for the designated period was dedicated to the project.
- Employees who contribute a portion of their time
(less than 100 percent) must complete a time and effort form documenting the
allocation of their time across projects, based on an after-the-fact
determination of the actual activities (i.e., time and effort cannot be
estimated in advance). For example, the
distribution of the time might be determined based on notes from personal
calendars and/or reasonable estimates of time spent on various activities.
4. The PI
and PD will ensure that appropriate personnel are trained in time and effort
reporting and ensure that time and effort is timely (at least monthly)
reviewed, authorized, and submitted to Financial Services by the PI, the PD, or
a designee, who has been identified to the Office of Government, Grants, and
Alumni, and who has direct knowledge of the work performed by the staff member
whose time and effort is being reported.
5. The PI
and PD will oversee the finances of his or her specific sponsored project(s); monitor
and authorize expenditures in accordance with the approved budget on file with
the funding agency; confirm that all authorized costs are reasonable,
allocable, and allowable under the terms of the grant agreement and approved
budget; and, ensure that appropriate documentation is collected and maintained
for each transaction. Financial Services
will serve as the official repository for this information to ensure that
documentation is maintained consistent with College policies and procedures and
6. The PI
and PD will ensure consistent implementation of College procedures related to
financial management, human resources, procurement, contract accounting, information
technology, and grants administration.
The PI and PD will consult as necessary with the administrative offices
that coordinate these functions.
7. The PI
and PD will supervise and monitor the work of subawardees and subcontractors
and will authorize payments to subawardees and subcontractors consistent with
the work performed. The
Management Services Office and the Office of Government, Grants, and Alumni
will work with PIs and PDs to establish agreements with any project partners
that will receive grant funding and/or have committed to support a specific
activity or deliverable associated with the grant project.
8. The PI
and PD will monitor and report on the financial status of each sponsored
project in relation to the sponsored project’s stated plan or objectives. Monitoring of spending and progress toward
program deliverables should occur at least monthly for the life of the project.
Federally sponsored projects require analysis of spending in relation to the
attainment of project objectives and a plan for addressing any misalignment
between proposed and actual spending and proposed and actual attainment of the
objectives outlined in the original grant proposal. The PI and PD will ensure timely preparation
of required documentation and provide to Financial Services and the Office of
Government, Grants, and Alumni for consultation, review, submission to funding
agency, and records retention.
9. Modifications to an approved project and/or budget
require prior, written approval from the funding agency. PIs and PDs are responsible for identifying if
modifications are needed and for working in collaboration with the Office of
Government, Grants and Alumni and Financial Services to request permission from
the funding agency to modify the project or project budget.
10. Financial Services will determine the applicable
indirect costs of a sponsored project in accordance with the federally-approved
indirect cost rate and guidelines of the grant program. In addition, if cost-sharing is required for
a sponsored project, Financial Services will authorize the funds to be matched
and will work with the PI and PD to collect and maintain required documentation
demonstrating the applicable cost-sharing requirement has been met.
11. The Management Services Office and the Office of
Government, Grants, and Alumni will collaborate with PIs and PDs and one
another to maintain an inventory of all equipment purchased with federal funds
with a useful life of one year or greater and a purchase price of $5000 or
equipment must be used for the project or program for which it was purchased
for as long as that project or program exists.
If the sponsored project or program no longer exists, the equipment must
be used for another federal project of the same funding agency or, if none
exists, a project of a different federal agency. If no other federal project exists, then the
Office of Government, Grants and Alumni and the Management Services Office will
consult with the applicable federal agency on the proper disposition of the
equipment must be maintained so as to minimize potential for loss or damage,
and accurate inventory records must be maintained to identify the equipment and
its specific location.
physical inventory will be conducted by the Office of Management Services, the
Office of Government, Grants, and Alumni, and the Facilities Department and the
results reconciled with equipment records at least once every two years.
12. All PIs
and PDs must comply with external and internal reporting requirements and
deadlines, allowing sufficient time for internal review and approvals. The
Office of Government, Grants, and Alumni reviews and submits final grant
reports to external funding agencies. Financial Services reviews and approves
all financial reports prior to submission. In addition, final reports are
posted to the shared Compliance Folder maintained by IPAR and the Compliance
Officer(s), and key outcomes are included in grant summary reports.
Approved by the OCC Board of Trustees September 27,