Policy Name: Post-Award Financial Management of Sponsored Projects
Responsibility for Maintenance: Government, Grants and Alumni; Financial Services
I. Policy Statement As a recipient of federal grants and other sponsored projects, Onondaga Community College is required to ensure:
PIs and PDs, with support from Financial Services and 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 documentation.
- Internal controls are in place so that grant funds are used solely for authorized purposes and consistent with applicable regulations;
- 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.
II. Reason for Policy 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.
III. Applicability of the Policy College faculty, staff, and all individuals and organizations funded through a grant award, including sub-awardees, are subject to this policy.
IV. Related Documents
| Subject || Office Name || Title or Position || Telephone Number || Email/URL |
| ||Administration and Compliance || Vice President, Administration and Compliance || (315) 498-2692 || [email protected] |
| ||Financial Services || Senior Vice President and Chief Financial Officer ||(315) 498-2668 || [email protected] |
- 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 include:
- Alumni activities and alumni relations
- Commencement and convocation ceremonies
- Creation 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
- Fund raising activities or materials
- Personal expenses, including memberships in social, dining or country clubs, and good or services obtained for personal use
- Investment management, bad debt losses, internal interest expense, fines and penalties
- Lobbying activities
- Public relations unrelated to the performance of the sponsored project
- Student activities, such as student clubs or intramurals
- Compensation of personnel in excess of federal salary caps
- 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.
- At the 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, Management Services, and 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 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 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, Administration and Compliance 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 President will determine the appropriate resolution.
- All 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 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 applicable regulations.
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. Management Services and 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 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 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. Management Services and 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 greater.
- Such 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 Government, Grants and Alumni and Financial Services will consult with the applicable federal agency on the proper disposition of the equipment.
- Such 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.
- A physical inventory will be conducted by Management Services, Government, Grants, and Alumni, and the department heads 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. 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 June 20, 2017