Policy statement and procedures
Adopted May 2009

Policy Statement

The University will follow the requirements of the Office of Management and Budget (OMB) the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, known as the Uniform Guidance or 2 CFR 200 and other applicable federal regulations with respect to financial reporting.  Uniform Guidance Subpart D §200.327-.329 set forth procedures for monitoring and reporting the grantee’s financial and program performance and list the standard reporting forms.   

Reason for Policy

The University has both financial and nonfinancial reporting requirements to federal agencies when it receives a grant award or federal subgrant. Agencies use timely and accurate reporting as one measure of grant monitoring. Sponsors often require interim and final technical and financial reports. Also, some agencies have moved to withhold future funding or freeze accounts if any reports, financial or technical, have not been submitted by the deadline. Therefore, it is important that the institution understand and comply with all mandatory reporting requirements.

Procedures

The Finance Office is responsible for managing the external financial reporting and invoicing requirements of sponsored research projects according to the terms of the grant award document. To do this, all members of the community who are responsible for administering sponsored projects will review and verify expenses on their accounts.

  1. Day-to-day responsibility for the financial management of a specific grant lies with the principal investigators (PI) and their administrative staff. They are expected to reconcile (verify that transactions on the account are correct) and monitor (check spending against the budget) their grant accounts regularly. On at least a bi-monthly basis the grants accountant will send an e-mail to each PI with their transactions and the status of their account. Both the PI and the grants accountant are responsible for retaining a copy of the verification of the account transactions. See the Direct/Indirect Charging policy for more information.
  2. A higher level of financial oversight should be conducted by the deans, department heads or directors. This level should focus on oversight and review of potential high risk areas. This level of review via PeopleSoft will provide information about patterns of spending and may highlight potential areas of improvement needed in operations.
  3. The University provides training on the use of PeopleSoft for financial management. The Finance Office can arrange such training on an as-needed basis.
  4. The Finance Office compiles and submits all required financial reports as required by the federal agencies. Principal investigators should not independently prepare or send billings or provide financial reports to sponsors. Sponsor requests for special billings or reports should be directed to the grants accountant in the Finance Office. Nonfinancial reporting requirements should be routed through the Office of Sponsored Programs to ensure compliance with federal agency guidelines.
    1. Quarterly financial reporting
      1. National Science Foundation (NSF) - Approximately forty days after every calendar quarter-end, NSF requires financial reports to be submitted. See Appendix A for detailed procedures.
      2. Department of Health and Human Services (DHHS) - Forty-five days after every calendar quarter-end, DHHS requires financial reports to be submitted. See Appendix B for detailed procedures.
    2. Annual financial reporting
      As part of the annual performance report to the sponsor, the PI is responsible for reporting technical program outcomes as well as financial information. This policy does not cover technical performance reporting (see Office of Sponsored Programs for guidance in this area). The financial component of the report should be prepared by the grant accountant. After these financials are reviewed and approved by the PI, the Office of Sponsored Programs has responsibility for transmission of these reports to the sponsor, often in conjunction with submittal of the technical report. The U.S. Department of Education requires specific financial reports to be included in their annual performance reports. See Appendix C for detailed procedures.

Forms/Instruction

  • None

Related Information

External Resources

Internal Information

Definitions

  • None

Responsibilities

Role Responsibility
Principal investigator (PI)
  • Manage daily the finances of the grant account.
  • Work with the Finance Office to reconcile any transactions in question.
  • Meet the sponsor’s deadlines and work with the OSP to submit the technical and financial reports in a timely manner.
Office of Sponsored Programs
  • Obtain financial reporting data from the Finance Office.
  • Work with the PI to submit the technical and financial reports in a timely manner.
  • Retain a copy of each report, financial or technical, as provided by the PI or the Finance Office.
Department heads and Deans
  • Provide general oversight and review potential high risk areas via PeopleSoft.
Provost
  • Establish effective processes and controls to ensure compliance with this policy, including dissemination of this policy to affected parties.
Finance Office
  • Perform a financial analysis of the grant account.
  • Invoice or bill sponsors.
  • Prepare final financial reports following agency guidelines.
  • Perform a post-award audit of expenditures.
Vice President of Administration and Finance
  • Establish effective processes and controls to ensure compliance with this policy.

Appendices

Appendix A: Quarterly Financial Reporting for NSF
Appendix B: Quarterly Financial Reporting for DHHS
Appendix C: Annual Financial Reporting for U.S. Department of Education

History

Origination date: May 2009
Last amended date: May 2020
Next review date: