Controller's Office Policy CO 03 10

A. Policy Statement

The department receiving the sponsored research award is responsible for the daily management and administration of the related funds.  This requires closely monitoring expenditures to assure that the terms and conditions of the award are being followed and that funds are being expended in accordance with the Uniform Guidance requirements for allowable, allocable and reasonableness, and in accordance with University policies.

It is the dual responsibility of the Principal Investigator (PI) and the Financial Manager (or designate) to monitor and approve all expenditures related to the sponsored project.  Any unallowable expenditures or deficit fund balances become the responsibility of the administering department to pay from another departmental fund and not from a sponsor award fund.

The original records and supporting documents of expenditures should be maintained by the department for three years.

Once the award is established, the Financial Managers (or designate) are responsible for reviewing the award document, reconciling it with the information on the Banner Financial and communicating any corrections or inconsistencies to the Post Award located in Lumbee Hall, room 312.

Fund transactions must adhere to the attributes, structure and funding methods established by Controller’s Office, and display fund numbers accordingly on forms for routing, approval, and electronic data processing.

Financial Managers (or designate) are requested to:

1.  Conduct Review of Award Documents
   • Identify restrictions.
   • Note reporting requirements.
   • Check for purchasing/spending authorizations under the award terms and conditions.
   • Initiate and maintain current financial information in Banner.
2. Set-up the Award Fund for Expenditures
   • Prepare personnel transactions upon assignment of a fund number.  Include personnel information that affects salary, such as salary caps, cost sharing, rate of pay compensatory to amount of full time effort (FTE), etc.
   • Create tracking for direct costs, F&A costs, sub awards, and consultant expenditures.
   • Establish deadlines for financial, progress and technical reports.
   • Monitor spending and prior approval requirements in light of the award funding.
   • Communicate regularly with those responsible for project activity to prepare requirements in a timely fashion.
   • Handle transactions and reconciliations by anticipating end-of-budget periods and other changes.
3. Use a Shadow System to Monitor Financial and Programmatic Transactions throughout the Life of the Award
   • Perform cost transfers.
   • Perform budget revisions.
   • Compare and balance award expenditures using Banner monthly reports.
   • Circumvent unallowable expenditures and overdrafts.

B. Reason for Policy

Providing such general responsibilities clarifies expectations and specific tasks of Post Award that are ascribed to Principal Investigators and Financial Managers (or designate).

C. Exclusions/Exceptions

Sponsored research often generates program income, such as fees for laboratory services, conference fees, third-party patient reimbursements, etc.  Treatment of program income varies by agency.  Thus, the Post Award officer should be notified in cases where program income is foreseeable or accumulates to establish the proper funding method to maintain such income in accordance in federal requirements.