Information and management procedures of grants for Effort & Travel on Sponsored Programs, Grant vs. Donation, Salary Corrections, Program Income, Pre-Award Cost, and Cost Overruns.
A cost overrun occurs when directs costs charged to a grant, cooperative agreement or contract are in excess of the awarded amount. Deficit spending on these funds is inappropriate and should rarely occur. When such an occurrence exists, the deficit must be moved from the grant, cooperative agreement or contract to a departmental account.
The departmental account to which the charges are being transferred should have the same function as the grant, cooperative agreement or contract. Specifically if the deficit fund has a function of research, the departmental fund should have a function of research. The same would follow if the function was instruction or other sponsored.
If the deficit is incurred in anticipation of additional funding, a memo should be prepared by the department accepting the responsibility for the cost overrun should the funding not be forthcoming. See preaward costs for criteria.
- Cost Transfer Policy
- Cost Transfer Explanation and Justification Form - Required for all cost transfers exceeding 90 calendar days.
- Cost Transfer Explanation and Justification Form Example
- P-Card Justification Form - Required for all P-Card reallocations.
- Journal Voucher Form - To correct voucher payments and to reallocate Purchasing Card expenditures.
- Retroactive Distribution Request Form and Partial Salary Correction Form - To correct payroll.
- Grants and Contracts Journal Entry Form - To correct non voucher payments other than payroll including Duplicating, Facilities, Library, Postage, etc. (10 lines or less)
- Grants and Contracts Journal Entry Form Example
- Journal Import Form - Replaces the Grants and Contracts Journal Entry Form when there are more than 10 lines.
All expenditures moved on or off a grant or contract fund require the completion of the Grant and Contract Journal Entry form. If the charge is greater than 90 days, the Cost Transfer and Justification form must be completed and accompany the Grant and Contract Journal Entry form.
Incorrect Funding Source
If the expenditure needs to be moved on or off a grant or contract, the Grants and Contracts Journal Entry form needs to be used to move this expenditure to the correct funding source.
You will need to complete the Grant and Contract Journal Entry form AND the Cost Transfer and Justification form.
P-Card Justification Form
You will need to complete the P-Card Justification form and the Grant and Contract Journal Entry form. You do not need to fill out the description on the GCJE form as that information is already entered on the P-Card Justification form. Please remember a Journal Import is needed if there are more than 10 lines.
P-Card Reallocation Date
You will go by the statement “for transactions posted between 00/00/0000 to 00/00/0000” ending date. If you are filling out a P-Card Justification form that is 90 days past statement end date you will need to complete the Cost Transfer and Justification form to accompany the Grant and Contract Journal Entry form.
Effort and Travel on Sponsored Programs
With the implementation of Cost Accounting Standards, the University needs to track all expenses associated with Grants and Contracts. This includes not only the charges on the Grant or Contract but all contributed effort or other Cost Share charges. UND must be able to account for all commitments made in a proposal even if we are not required to report them to the sponsor. Therefore be aware that if you are including time and effort for UND faculty or staff in a proposal, they will be required to certify to their effort through our Personnel Activity Confirmation System.
Cost Accounting Standards also apply to reimbursement of travel on grants and contracts. Travel on a grant or contract is allowable if the individual is receiving salary from or documenting effort on that funding source.
- The "Fly America Act" and what it means to your international travel plans.
- Fly America Act - Exception Request Form
Grant vs. Donation
This checklist is intended to assist staff with the appropriate classification of external support. Some judgment will be required to classify an award if items are checked in both areas. Each award must be considered in the whole rather than any single element. This checklist is not intended for direct federal grants and cooperative agreements.
- Budget restrictions or formal financial accounting during the life of the project
- Objectives to be achieved by the use of funds
- Subcontracts (where we are receiving funds as the Subcontractor)
- Prior approvals from sponsor required
- Key personnel are listed
- Period of performance
- Invention/data rights (intellectual property)
- Binding legal relationship (obligates recipient to perform and sponsor to pay)
- Deliverables are part of the agreement
- Reporting requirements (financial or technical)
- The sponsor retains authority to withhold funds pending satisfactory completion of project objectives
- Cost sharing
Gift or Donation
- No contractual requirements. However, objectives may be stated and use of the funds may be restricted to a particular purpose (professorship, scholarship, travel or research in a defined area - e.g. diabetes).
- Award is irrevocable.
- No period of performance is specified.
- Formal financial accounting is not required and there is no requirement to return unexpended funds. However, a report to the donor on the utilization or impact of the gift may be requested.
- The cash is received prior to incurring any expenditures.
Sometimes it is necessary to have a fund and project established prior to the execution of the final award document. These guidelines outline the requirements for establishing an account that will be used for pre-award costs. It is inappropriate to charge pre-award costs to a non-sponsored account and transfer them later. The following criteria apply:
- The request should contain a description of the sponsor assurance.
- The anticipated award amount.
- The projected start date of the award.
- The department must accept the financial risk in the event an award is not forthcoming, the start date is changed by the sponsor or an acceptable agreement can not be negotiated.
GCA reviews and approves the request and sets up the fund and project.
Program income means gross income earned by UND that is directly generated by a supported activity or earned as a result of a grant, cooperative agreement or contract. Program income includes, but is not limited to:
- Conference fees.
- Income from fees for services performed.
- The sale of commodities or items fabricated under an award (books, videos, etc.).
- The use or rental of property acquired under a grant, cooperative agreement or contract.
- License fees and royalties on patents and copyrights.
Program Income Usage
Program income will be used in one or more of the following ways:
- Additive alternative. Program income is added to the funds already committed to the project. It is used to further eligible project or program objectives under the terms of the award.
- Matching alternative. Program income is used to finance part or all of the matching costs of the project or program.
- Deductive alternative. Program income is applied toward the allowable project cost during the award period. Thereby reducing both the sponsor share and the matching share.
- No restrictions. Program income can be used by the department as they see fit. Expenditures must follow University Policy.
Program income that is earned during the award period and falls under the alternatives one to three listed above, must be expended during the award time frame. If the additive or matching alternative is in effect and all of the program income can not be spent during the award period the excess would be used in accordance with the deductive alternative.
The following examples illustrate the alternatives.
An agency awards $100,000 for a project. The project generates $10,000 of program income.
- Additive alternative. The total project cost could now be $110,000.
- Matching alternative. If UND were required to provide a 20% match ($20,000 - UND and $80,000 - Agency) the project would be reported as follows:
$10,000 program income
$10,000 UND match
- Deductive alternative. The agency would now only fund $90,000.
Purchasing Card (P-Card) Reallocation for Grants & Contracts Activity
Purchasing Card Info Sheet - Guide to Purchasing Cards questions. Answers where P-Card documents should be sent and provides a checklist to assist with submitting all of the appropriate forms.
Purchasing Card Reallocation Forms
- Journal Voucher Form - Required for all P-Card reallocations. For more than 5 lines, attach additional
Journal Voucher forms as needed.
- Vendor ID for JP Morgan is 0000111577.
- Vendor Name is JP Morgan.
- Related Voucher Number (Document ID#) may be found on the budget transaction detail report.
- Justification on the Journal Voucher form may state “Please see P-Card Justification form” if all the information is included on the P-Card Justification form.
- P-Card Justification Form - Required for all P-Card reallocations.
- P-Card Justification Form Example
The function of the GCA is to properly administer sponsor funding. After the fact salary adjustments are always carefully monitored due to sponsor requirements. If an adjustment is necessary, the correction should be done in a timely manner (within 90 days). No corrections should be requested after effort has been certified on a Personnel Activity Confirmation form.
In order to be consistent with Appointment Revision Forms and have an accurate audit trail for both internal and external auditors, a UND Retroactive Distribution Request and a Partial Salary Correction Form have been developed to assist in submitting the necessary information and can be found on the Payroll website. The form should be used for all Salary Corrections and will require the signature of the Principal Investigator.
Summer Salary with Grant, Cooperative Agreement or Contract Funding
The following is being provided for faculty with nine-month appointments and being paid on a grant, cooperative agreement or contract during the summer.
- Faculty having nine-month contracts may be employed for up to three full months' salary on research grants or other sponsored program activities provided the sponsoring agency's rules do not prohibit such salary payments and the total cumulative salary being paid to the faculty member from all University sources does not exceed the equivalent of three months salary. Section III Part 5.1.2 of the Faculty Handbook
- This includes salary from grants, cooperative agreements, contracts, teaching responsibilities, and summer graduate research professorships'.
- Summer salary of nine-month faculty should be charged to federal grants at a rate no greater than 100% of the base salary for compliance with Federal OMB Circular A-21, Principles for Determining Costs Applicable to Grants, Contracts, and Other Agreements with Educational Institutions.
- Base salary used for computing summer salary will be the base salary of the faculty member's current academic year appointment (that ends May 15th) divided by the number of months in their academic year contract. This amount would be the monthly salary rate and would be used to calculate the summer salary for the period May 16th through August 15th. For example, a nine-month faculty member with a base salary of $90,000 for the current academic year ending May 15th would have a summer salary rate of $10,000 per month ($90,000/9 months = $10,000).
- The annual increase in base salary, for nine-month faculty, is not effective until August 16th of each year.
- Normal research assignments are not considered overload.
- If you are paying yourself a full summer salary (three full months), your time commitments should reflect a full time work schedule.
A When a department funds a graduate assistantship from a grant or contract and pays tuition remission for the student, both the assistantship and tuition remission must be paid from the same grant or contract project number. Graduate Assistant salaries are paid semi-monthly through Payroll and tuition remission is processed through Student Financial Aid at the beginning of the academic term. When the funding source changes for the graduate assistantship for one or more pay periods the department MUST PROCESS a journal voucher to correct the funding source of the tuition remission so it agrees with the salary funding source.
Tuition remission for graduate assistantships on grant or contract funding covers the amount of tuition only. Fees, including continuing enrollment, are normally not an allowable cost on a grant or contract.
Uniform Guidance & Federal Requirements from OMB
The Federal Government has issued new Uniform Guidance (UG) for Federal or Federal Flow Through awards. The Office of Management and Budget has combined Educational Institutions, State and Local Governments, Non Profits and Tribal Governments into one document for dealing with Federal Awards. The new document is the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. The Final Guidance was published in the Federal Register on 12/26/13 and will become effective for awards made on or after 12/26/14. The Uniform Guidance which supersedes A-21, A-87, A110, A-122, A-89, A-102, A-133 and A-50 can be found at the following site.
The UG is broken down as follows:
- Subpart A – Acronyms and Definitions
- Subpart B – General Provisions
- Subpart C – Pre-award Requirements & Contents of Federal Awards
- Subpart D – Post Federal Award Requirements
- Subpart E – Cost Principles
- Subpart F – Audit Requirements
- I Funding Opportunities
- II Contract Provisions
- III Indirect Costs (F&A)
Following are some of the changes in the UG.
- Compensation – they have removed the examples that were in A-21, Cost Principles for Educational Institutions, and they have put more emphasis on internal controls. The internal controls and new methods to capture salary and wages charged to Federal awards come with some very high expectations. Currently this will not cause any changes at UND as Effort Reporting is still an acceptable methodology.
- Supplies – it states that computing devices qualify as supplies and are allowable if they are under $5,000. You will also need to make sure the computing devices are allocable (justified usage) to your award.
- Procurement Standards – have become more stringent and we may have to rethink how purchases are made on Federal awards. There is a new Micro-purchase threshold, it is currently set at $3,000, the expectation is any amount $3,000 and greater will require quotes or bids. This will have an impact on purchasing of goods and services and usage of the P-card.
- Conflict of Interest – the guidance requires all Federal agencies to establish a conflict of interest policy for Federal awards. This may become messy if agencies have different policies.
- Expanded Authority – which includes preaward spending, relief from prior approvals, research terms and conditions are not recognized in the new UG. We are hoping this may be addressed in agency specific guidance but are looking for other avenues to get these administrative burdens reduced.
- Administrative Costs – may be treated as direct costs when they meet certain conditions and they must be in the budget and justified, otherwise they need agency approval.
- Cost Sharing – will only be considered during merit review if it was required by regulation and was in the notice of funding opportunity. Therefore providing cost share will not cause a proposal to be rated any higher.
- Indirect Cost – for entities that do not have an approved Indirect Cost Rate you can provide them a 10% de minimis rate of Modified Total Direct cost. Also pass through entities must recognize the Federally approved negotiated indirect cost rate between the Federal government and the subrecipient.
This listing is not all inclusive but will give you an idea of some of the changes and challenges we face. Further information and clarification will be provided as the issues are worked through and additional information becomes available.