Frequently Asked Questions Regarding Sponsored Project Administration

As principal investigator I've decided I need to spend award funds differently from what was proposed and awarded. is this okay?

Each award is potentially different from any other award. The first rule of thumb is to read the section for the award terms and conditions usually called re-budgeting. Many awards make reference to an overriding set of guidelines or, in the case of some federal awards, to an Office of Management and Budget (OMB) circular. Become familiar with all of your awards so that you know where to look for this information. When the answer still seems unclear, contact the Office of Research.

Can alcoholic beverages be charged to a federal award under any circumstances?

No. There are no instances when alcoholic beverages would be either appropriate or allowable, unless the awarding agency specifically provides approval in the award notice.

Can a foreign air carrier be used (and subsequently charged to a federal award) if it is a "partner" with a U.S. air carrier?

Yes, but only under certain conditions. Travel should always be planned in advance of the trip to ensure that space will be available on an appropriate air carrier. When dealing with travel agents, specify that the air carrier must be of U.S. origin. When no U.S. air carrier is available, be sure to check the criteria for what the government considers "available" and "non-available". Refer to your sponsor's guidelines for further information. Most federal links are available on the Research & Sponsored Programs Accounting Web Page.

I have what looks like an invoice from a subcontractor under one of my awards. What do I do with it?

As principal investigator, you are in the best position to know whether expenses charged on a subcontractor's invoice appear reasonable, necessary, and in accordance with the approved project terms. If you have objections or questions regarding the expenses, contact your collaborator on the subcontract. After any issues are resolved, indicate your approval in writing and forward the invoice, with any attachments, to Research & Sponsored Programs Accounting. Your RSPA Administrator will prepare the payment request and review the subcontract budget to ensure funds are available.

What are indirect costs?

Indirect costs, also known as overhead, and now officially known as facilities and administrative costs (F & A Costs), are those costs that cannot be charged as direct costs to a sponsored project. The amount charged is based upon a rate that reflects the University's negotiated and federally approved rate or, if conditions warrant, a lesser rate abased upon such things as a maximum percentage or amount allowed by a sponsor. Please note: RSPA does not have the authority to reduce or waive indirect costs in an award budget. The amount charged is intended to pay for such costs as utilities, building maintenance, snow removal, administrative salaries, etc.. Click on Indirect Costs for a more detailed explanation of this subject.

If I know exactly how much time our department's administrative assistant spent working on my project, why can't I charge that portion of his/her salary to my federal grant?

In OMB Circular A-21, Cost Principles for Educational Institutions, the federal government specifies certain costs that "normally" should be charged only as indirect costs. Administrative assistants fall under that category. To claim any of the specified charges as direct costs, you must justify within the project's proposal why the costs are necessary, reasonable, and uniquely and solely attributable to the project. The potential sponsor will determine whether the expense may be allowed.

What's the difference between an employee and a consultant?

The term "hire" suggests that the relationship to be created is that of employer/employee. Consultants are, instead, "engaged" to provide services that must be unique in nature and otherwise not available through the University. Planning is key in the use of consultants (also referred to as independent contractors). The services to be provided by a consultant should be disclosed and justified within the award proposal. Please see Section 4. of the Sponsored Project Handbook (see page 7) for information on expenditures involving consultants or contact Research Accounting for advice on how to proceed.

How can I get expenses that were mistakenly charged to one award transferred to the correct award?

Federal sponsors closely scrutinize cost transfers. Frequent or untimely transfers leave the principal investigator open to questions regarding lax oversight or inappropriate spending of award funds. Therefore, the principal investigator should frequently review the account activity and identify in timely fashion any inappropriate charges to an award. However, mistakes happen. If you do identify errors on your account, you'll need to complete a Cost-Transfer Form. Use the form to describe and justify the need for any transfer of expenses. It is not acceptable to request a transfer simply to use funds remaining on an award about to expire. Generic descriptions, such as "Due to administrative oversight," are not acceptable. All cost transfers must be completed within 90 days of the original transaction. Exceptions must be discussed with Research & Sponsored Programs Accounting. Consideration to the issue will be given, but approval is not guaranteed. Repeated requests for transfers could require a written action plan detailing procedures to be implemented to ensure more accurate record-keeping.

What is the difference between cost sharing and matching?

Both cost sharing and matching achieve a similar objective: to provide funds in addition to the sponsor's award toward the total costs of a project. Typically, cost sharing occurs when the University uses its own funds for this purpose, while matching takes place when the University raises funds from another source. Matching can also occur in situations where a sponsor requires the University to "match" what it provides on the basis of some prescribed formula (e.g., one for one match).

Who is responsible for keeping track of the costs incurred with either cost sharing or matching funds?

Like the expenses incurred on any sponsored project, the recipient is responsible for overseeing the expenditure of all cost sharing and/or matching funds. Accordingly, you must ensure that all expenditures of cost sharing and matching funds meet the allowability requirements of the sponsor providing the primary award. Research & Sponsored Programs Accounting will include cost sharing and/or matching funds expenditures on the financial reports required by your sponsor.

Why do I and anyone else charging salary to my federal award, have to sign Personal Activity Reports?

When proposals are submitted, the University is "promising" that, should the sponsor make an award to Notre Dame, certain things are going to happen. One of those things is the devotion of effort by personnel who are key to the project. The Office of Management & Budget Circular A-21, Cost Principles for Educational Institutions, Sect. J.8.c (e) requires a formal personnel activity reporting system as a means of documenting such promised effort has taken place. The University uses Personal Activity Reports (PAR) to fulfill that obligation.

The PAR is based on the Employee Status Form designating the amount of salary you are to receive, and the accounts to which your salary is to be apportioned. When you sign a PAR, you are certifying

  1. performance of the work in accordance with your award guidelines, and
  2. the amount of salary charged to the award is commensurate with the amount of effort expended on the project.

If, during the period covered by the PAR, you did not expend the amount of effort anticipated by your Employee Status Form you must contact Research & Sponsored Programs Accounting to assist you in making an immediate correction to payroll records.

I'm confused about how to read my online financial reports.

Carol Grontkowski, Financial Systems Analyst, or Research & Sponsored Programs Accounting are resources for training on the Banner Financial System.

I'm not sure how to initiate transactions against my sponsored project accounts. Who can I turn to for help?

Check out the Guide to Restricted Funds available on the RSPA web site. It will lead you through most basic transactions. If you still have questions, contact the accountant identified in the e-mail announcement of your restricted account.

Don't all awards come with a check attached?

Most awards, in fact, are simply authorization for the faculty to begin incurring expenditures in furtherance of project goals. Research & Sponsored Programs Accounting is responsible for requesting funds in accordance with sponsor guidelines in order to receive reimbursement for expenses incurred by the project.

What happens when an award has ended?

Most sponsor guidelines require reports to be filed within 90 days of an award's expiration date. Subcontracts under awards to another institution generally have a 60-day window for submitting all required paperwork. Therefore, bills and reimbursement requests must be processed within 30 days following the awards end date.

The responsibilities to close out awards are split three ways:

a. Office of Research

i. Patent Reports

ii. Intellectual Property Reports

b. Research & Sponsored Programs Accounting

  • Financial Reports
  • Property Reports

c. Principal Investigator

  • Technical Report

I have money left, and my award is ending in 30 days. Why did Research & Sponsored Programs Accounting deny my purchase orders for equipment and lab supplies? I didn't use my full budget for either category.

Although your request may have been within budget guidelines, you did not appear to satisfy the requirement for purchases to be reasonable and necessary for performance of the project. It is imperative, therefore, for the Principal Investigator to submit all requests for transactions in a timely manner. All goods ordered (both supplies and equipment) should have been ordered at least 90 days prior to the end date of an award and promptly received in order to justify usefulness to the completion of the project.

What constitutes a business meal?

While there is no one definition, the consensus at the federal level appears to be that business meals are "working" meals where food and beverages are brought in to the meeting room while discussions continue. this interpretation has been indicated emphatically in discussions with the policy offices of both the Department of Health & Human Services (DHHS) and the National Science Foundation (NSF). The issue is whether or not it is necessary to "break" for lunch. When this happens, as in the case where a meeting is interrupted to physically travel to a restaurant, the meal is no longer considered by these agencies to be business in nature. To avoid confusion and leave transactions open to interpretation, departments should plan ahead and incorporate any meals that are necessary into the meeting agenda. Where a consultant is involved and would be eligible for reimbursement under the terms of the agreement for services, the meal of the consultant normally will be allowable, regardless of whether or not it is a business meal.

If I am traveling on University business and need to meet over lunch with a colleague to discuss my research, may I charge the lunch to my federal award?

Unless the colleague happens to be a Notre Dame employee who also is on official travel status for the University, working on the same award and, therefore, entitled to be reimbursed under the travel budget of that award, the meal would not normally be considered an appropriate business meal, i.e., only your meal would be allowable.