I. GENERAL
II. AUTHORIZATION OF EXPENDITURES
III. COST-SHARING
IV. PERSONNEL REGULATIONS
V. TIME AND EFFORT REPORTING
VI. PURCHASING
VII. TRAVEL AUTHORIZATIONS
VIII. CONSULTANTS
IX. EQUIPMENT
X. EXCESS GOVERNMENT PROPERTY
XI. NEGOTIATIONS OF POST-AWARD CHANGES IN
PROJECT
XII. PURCHASES NEAR TO AND AFTER TERMINATION
DATE
XIII. RETROACTIVE COST TRANSFERS
XIV. CLOSE OUT AND AUDIT
XV. MISCELLANEOUS
LINKS TO EXHIBITS
It is the policy of the University to permit as much flexibility as possible to the project director in pursuance of the research or training objectives. However, awards for sponsored projects are made to the University, not the project director, with the University identified as grantee. The University thus assumes full responsibility for insuring that the program is conducted within the administrative guidelines and regulations specified by both the sponsoring agency and the University. It is the primary responsibility of the Office of Research and Sponsored Programs, as the designated institutional representative, to serve as intermediary between the agency and the project director for the purposes of negotiating changes in the project budget, modifications (reallocations, increase or decrease of funds), time extensions, and other items primarily administrative in nature. The project director has the responsibility for directing the technical aspects of the project and otherwise carrying out the research or program effort within the scope authorized by the agency and for initiating any and all expenditures of grant funds within budget and contract constraints. The Grant Accounting Office is responsible for all post award accounting and reporting activities.
Project expenditures and equipment
accountability on all Federally sponsored projects are governed
by Office of Management and Budget Circulars A-21 and A-110. In
addition, each Federal Agency publishes a guide or policy
statement on their grants which generally encompasses the
requirements in A-21 and A-110. The project director should be
familiar with these publications. Expenditures must conform to
those guidelines as well as all University requirements.
Purchase requisitions and travel authorizations must be
processed through regular University channels and in accordance
with existing University guidelines contained in other sections
of this policy and procedure manual. General procedures for
grants and contracts are as follows:
Back to Top
II. AUTHORIZATION OF EXPENDITURES
When an award has been accepted by the
University, the Office of Research and Sponsored Programs
forwards to the Financial Services Office a copy of the award
notice, and a complete grant application with detailed budget
and preferably an agency financial manual. A conference is
scheduled with the principal investigator and Accounting Office
personnel for discussion and explanation of (1) project budget
line items, (2) time and effort reports, (3) budget revision
process and requirements of the Agency and the University, (4)
progress and technical reports required, (5) purchasing
procedures, (6) close out procedures, and other items as
appropriate. The grant account number to which charges are to
be made is released at this time.
Back to Top
Historically, federal agencies require
auditable cost- sharing on the part of the University for
government supported projects. The University usually has the
option of meeting this cost-sharing requirement in a number of
ways. The University can cost-share (a) a percentage of the
time and effort of the personnel involved in carrying out the
project; (b) part of the indirect cost; (c) operating expenses,
etc. University cost-sharing is generally indicated at the time
the proposal is submitted. The amount of cost-sharing required
and the method of meeting that requirement will be indicated
upon the face of the Notice of Award. In addition, any
administrative notes attached to the award notice will usually
indicate what is required of the project director as far as
documentation of personnel time and effort, etc., to meet the
cost-sharing requirements.
Back to Top
All personnel involved in the project
whether they are faculty, professional staff, clerical, or
students, must be paid in accordance with Tennessee Board of
Regents and University guidelines.
Back to Top
V. TIME AND EFFORT REPORTING
The project director is responsible for the preparation and timely submission of the required University forms delineating the total effort of all personnel working on the project, whether charged directly to the grant or contract or used as University cost-sharing. Time reporting copies are based on each person’s signed time report generated by the TRS system.
Requisitions for supplies and equipment are
initiated by the project director and must be submitted in
accordance with the established University procedures for the
purchase requests. Care must be exercised to insure that
contract and grant funds are expended only for budgeted items
and that the total amount of funds provided are not exceeded.
Back to Top
When funds have been provided in the
approved budget for travel, domestic or foreign, the project
director is responsible for initiating the required travel
authorization forms and submitting them through regular
channels for approval.
Back to Top
Due to federal audit requirements, the University must apply the same regulations to consultants hired on all research and sponsored program grants. Unless the federal grant or award specifies otherwise, the federal government will not participate in paying for overload or overtime. The payment for consultant services may not exceed the daily equivalent of the maximum rate paid a United States Government GS18 employee. Please contact the Office of Research and Sponsored Programs for the current maximum rate. Federal guidelines require that:
A. There is evidence that the services to be provided are essential and cannot be provided by persons receiving salary support under the grant or otherwise compensated for their services.
B. A selection process has been employed to secure the best qualified person available.
C. The charge is appropriate considering the qualifications of the consultant, normal consulting charges, and the nature of the services rendered.
D. If the individual is an employee of the
grantee institution, consultation is across departmental lines
and in addition to the regular duties or involves a separate and
remote operation, and the work performed is in addition to the
consultants normal departmental work load. Written requests from
academic departments for consultant services are to be submitted
to the Provost or Vice President for Health Affairs as
appropriate. Departments other than academic are to submit
requests to the Vice President for Business and Finance. When
using an outside consultant, a personal service contract must be
completed in accordance with the procedures in
FP-14
.
Back to Top
Equipment is defined as a physical resource
that benefits a program for more than three years (one year for
Federal projects) and costs in excess of five thousand dollars
($5,000). The definition of equipment for sponsored research
varies from agency to agency. The agency's definition of
equipment, if more restrictive than the state's definition,
would govern. For information regarding the regulations of each
agency with which you are dealing, please contact the Office of
Research and Sponsored Programs. In general, any purchase of
equipment must have been specified in the approved operating
budget prior to its purchase. Deviation from the approved
budget for equipment purchases must be submitted to the Office
of Research and Sponsored Programs for required agency approval
prior to purchase.
Back to Top
X. EXCESS GOVERNMENT PROPERTY
Information on the acquisition of excess or
surplus government property under a grant or contract is
available from the
Purchasing Office
.
Back to Top
XI. NEGOTIATIONS OF POST-AWARD CHANGES IN PROJECT
All sponsoring agencies have specific
requirements on the approval process which must be adhered to for
changing the approved scope or work, in reallocating funds from
the approved operating budget, changing the total effort to be
devoted to the project by senior personnel, or changing the
approved time for the project. In some instances approval must be
obtained from the sponsor, while in other cases the University
has been given the authority by the sponsor to approve such
changes. Project directors must consult the
Office of Research and Sponsored Programs
on all proposed changes in these categories.
Back to Top
XII. PURCHASES NEAR TO AND AFTER TERMINATION DATE
Items not received during an award period are
not of benefit to the project and are routinely disallowed on
audit, even if they were legitimate charges at the time the order
was placed. Therefore, orders for supplies and equipment must be
placed well in advance (60 - 90 days) of the grant expiration
date to ensure delivery. If additional time is needed to complete
reports or acquire supplies, contact the
Office of Research and Sponsored Programs
to aid in securing a no-cost time extension
or to make other arrangements.
Back to Top
XIII. RETROACTIVE COST TRANSFERS
Expenditures should always be charged to the proper account initially. However, transfers must occasionally be made. An Addendum to Public Health Service Grant Manual is typical of Federal requirements:
A. The cost is a proper and allowable charge to the grant.
B. The transfer is supported by documentation, fully explained and justified.
C. The transfer is reviewed and approved by
the University Financial Services Office and unless an obvious
error was made in the original charge the transfer must be made
within 120 days of the original recording of the transaction.
Back to Top
Technical and financial close-out documents
are due soon after the termination date of the grant. The
project director is responsible for preparation of the
technical report to the granting agency and will be required to
provide information, when requested, on possible patents and
property acquisition as well as signing the final expenditure
report. Most awards are audited under the provisions of the
single audit concept as contained in OMB Circular A-133. Under
this OMB Circular, the Division of State Audit performs
compliance and financial testing of grants and contracts during
their normal audit of the university with the results reported
to the university’s cognizant audit agency. However, the
agency may perform a separate audit. Project directors should
keep complete, accurate records in case the award is selected
for comprehensive audit.
Back to Top
The project director is the administrator of
the project. The Financial Services Office will record and report
the financial transactions of the project in accordance with the
approved project budget. Project directors who have concerns or
questions regarding accounting procedures, payments under grants
and contracts, cost-sharing, staff benefit charges, or indirect
costs should contact
Financial Services
or the
Office of Research and Sponsored Programs
, as appropriate.
Back to Top
Exhibit 8. A - Memo for Establishment of
Preaward Account Number
on the Office of Research and Sponsored
Programs website
http://www.etsu.edu/research/forms.htm
Exhibit 8. B - Re-budgeting Prior Approval
Sheet
Word Format
Original effective date: April 9, 1982
Revised: October 1, 1987; November 1, 2001; February 22, 2010,
January 7, 2011
Last review: January 7, 2011