Frequently Asked Questions
How do I know which costs are appropriate to charge to a sponsored project?
Project expenditures should be allowable, allocable and reasonable. Allowable means expenses must be treated consistently through the generally accepted accounting principles appropriate to the circumstances and conform to any limitation or exclusions set forth in the sponsored agreement or in Federal Cost Principles (2 CFR Part 200, Subpart E). For an expense to be allocable to sponsored project it must be incurred to support or advance the work or the specific sponsored award. If the cost benefits more than one award, it must be allocated in realistic proportion to the benefit provided. Finally, costs are considered reasonable if they can withstand public scrutiny.
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 award terms and conditions addressing 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. For assistance with re-budgeting, please contact the Office of Research’s Post-Award Financial Management group.
What do I do with invoices from a subcontractor?
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 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, review the subcontract budget to ensure funds are available and generate the payment based on the vendor terms.
How can I get expenses that were mistakenly charged to an 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 identify errors on your account, please complete the appropriate cost transfer form (e.g. Manual Journal Voucher or Labor Distribution Change). Use the form to describe and justify the need for any transfer of expenses. Please contact ND Research Administration’s Grant Program Management group for assistance completing this form.
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 discovery. Exceptions to this policy 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. For additional information, please consult the University’s Cost Transfer policy.
Who is responsible for keeping track of the costs incurred with cost sharing or matching funds?
Similar to expenses incurred on any sponsored project, the principle investigator 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.
RSPA will include cost sharing and/or matching funds expenditures on the financial reports required by your sponsor.
How do I initiate transactions against my sponsored project accounts?
The process of charging expenditures to a sponsored project varies depending on the type of expense. Please contact the Grants Business Management team in the Office of Research for assistance with your purchasing and hiring needs.
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:
ND Research Administration
1. Patent Reports
2. Intellectual Property Reports
Research & Sponsored Programs Accounting
1. Final Invoices
2. Financial Reports
3. Property Reports
1. Technical Report
I have money left, and my award is ending in 30 days. Why was my purchase order for equipment denied?
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 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.
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. For additional information please refer to the University’s Meals on Sponsored Projects Policy.
How long are payroll and benefits encumbered?
Payroll and benefit encumbrances are currently encumbered through an employee’s termination date or the end of the current fiscal year, whichever comes first.
How are fringe benefits charged to my funds?
Fringe benefits are charged to the same funding source(s) as individuals’ salary/wages based on annually adjusted benefit rates. The university currently has eight unique benefit rates for the following groups: Full-time Faculty, Part-time Faculty, Post Doctoral Staff, Exempt Staff, Non-exempt Staff, Temporary Staff, Undergraduate Students and Graduate Students. The current fringe benefit rate can be found on RSPA’s section of the Controller’s website.
Can I charge a local business meal to my grant?
Generally, intramural meals, such as lab meetings, where participants are solely University employees, are not allowable as charges to federal grants (See NSF Proposal and Award Policies and Procedures Guide and HHS Grants Policy Statement). However, in some cases business meals may be allowable if ALL the following are met:
· The sponsor does not specifically disallow such costs
· The meeting includes significant participation of external collaborators
· The meal is part of a formal meeting and maintains continuity of the meeting
· The activity at which the meal is served is integral to the goals of the project
If all these conditions are met, additional documentation must be provided to substantiate allowability. Items such as an attendee listing (including title and relationship to the project), a meeting agenda and the business purpose for the expense must be included. Where a consultant or collaborator is involved and would be eligible for reimbursement, the meal of this individual normally will be allowable, regardless of whether or not it is a business meal. For additional information please refer to the University’s Meals on Sponsored Projects Policy.
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. In general, employees cannot function as an independent contractor.
How do I read my GLez reports?
See GLez Frequently Asked Questions for help in reading Glez reports.
Are there other financial reports available to help monitor a sponsored project?
The Office of Research’s Post-Award Financial Management group provides financial reports and projections for PIs to help monitor and plan grant expenditures.
Who prepares and signs off on financial status reports?
Financial status reports for all grants and contracts must be prepared and submitted by Research and Sponsored Programs Accounting.
When are financial status reports due?
Interim Federal financial reports are generally due within 30 days of the end of the reporting cycle they apply to (monthly, quarterly, etc). Final Federal financial reports are due within 90 days after the end of the award. Due dates for non-federal funds vary from sponsor to sponsor and are usually defined in the award documentation.
Don’t all awards come with a check attached?
Most federal awards are simply authorization for the faculty to begin incurring expenditures in furtherance of project goals. Awards from Private sources are generally paid according to a scheduled plan contained in the award document. In either case 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 is the collections process? Who bills the sponsor? How is the invoice generated?
This depends on the sponsor and the agreement type. Most federal agencies, such as the NSF and NIH, pay via letter-of-credit draw-down. Early in the month funds are drawn down electronically from the sponsor to match prior month’s expenditures, as long as the expenditures are within the budget. For many non-federal awards, the sponsor will pay based on a predetermined schedule or may pre-pay the entire award.
Who is responsible for the timely collection of Accounts Receivable balances?
Collection is a collaborative effort between RSPA and the PI. The PI must ensure timely submission of progress reports and RSPA must provide timely billing support.
What is the Uniform Guidance (2 CFR 200)?
The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) was issued by the Office of Management and Budget on December 26, 2013 and went into effect on December 26, 2014. The Uniform Guidance is intended to serve as a single place where all financial management regulations applicable to federal awards can be found. The Uniform Guidance replaces the long-standing OMB Circulars A-21, A-110 and A-133. These regulations are codified in 2 CFR 200 within the Federal Register.
What are typical allowable and unallowable expenses on sponsored research awards?
2 CFR 200, Subpart E (formerly A-21) defines allowable and unallowable costs on federally funded research awards. Allowable costs are comprised of direct costs necessary to the performance of the sponsored agreement, plus the allocable portion of facility and administrative costs. Costs are generally considered allowable if they are reasonable, allocable to the sponsored agreement and are given consistent treatment through application of the generally accepted accounting principles appropriate to the circumstances. Allowable expenses must also conform to any limitations or exclusions set forth in these principles or in the sponsored agreement.
The following items are considered unallowable per Subpart E of 2 CFR 200:
- Advertising and public relations
- Expenditures to promote the University are not allowable
- Advertising for recruitment of employees or human subjects is allowable
- Alcoholic beverages
- Bad debts
- Commencement or convocation costs
- Contingency provisions
- Office supplies
- General-use equipment
- Charitable contributions, donations, remembrances – However the value of donated services may be used to meet cost sharing or matching obligations
- Commercial air travel costs in excess basic least expensive unrestricted accommodations class offered by commercial airlines
- Development/fundraising costs
- Entertainment costs: Costs of entertainment, including amusement diversion, and social activities and any costs directly associated with such costs (such as tickets to shows or sporting events, meals, lodging, rentals, transportation, and gratuities)
- Fines and penalties
- Goods or services for personal use of employees (including gifts)
- Housing and personal living expenses of University officers
- Investment management costs
- Losses on other sponsored agreements or contracts (cost overruns)
- Any excess of costs over income under any other sponsored agreement or contract of any nature is unallowable. This includes, but is not limited to the institutions contributed portion by reason of cost-sharing agreements or any under-recoveries through negotiation of flat amounts for indirect costs.
- Pre-award costs, unless approved by the sponsoring agency or permitted under expanded authorities
- Selling and marketing costs of any products or services of the institution
- Student activity costs incurred for intramural activities, student publications, student clubs, etc.
- Interest expense – However, interest paid to external parties that is associated with the acquisition of equipment or other capital assets is generally allowable.
Depending on the circumstances, other items of cost may be deemed unallowable as well.
What can I do to ensure financial compliance for funded projects?
The key to financial compliance is to understand and follow 2 CFR 200 and any other sponsor or University regulations. When managing sponsored funds on a daily basis ask the appropriate questions to ensure costs are reasonable, allocable and consistently treated. When you have questions, please consult with a Grants Business Manager or Post-Award Grant Project Manager from ND Research Administration or staff from Research and Sponsored Programs Accounting.
How long should I keep my grant-related records?
2 CFR 200.333 states “Financial records, supporting document, statistical records, and all other non-Federal entity records pertinent to a Federal award shall be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as authorized by the Federal awarding agency or pass-through entity in the case of a subrecipient.”
If any litigation, claim or audit has started before the expiration of the 3-year period, the records need to be retained until all litigation, claims or audit findings involving the records have been resolved and final action taken.
Records for real property and equipment acquired with Federal funds need to be retained for 3 years after final disposition.
Because the period of a grant may range from 1 to 10 or more years, the 3-year rule needs to be considered together with the length of the grant.
Can alcoholic beverages be charged to a federal award under any circumstances?
Alcoholic beverages can only be charged to a federal award if the cost was included in the proposal which the agency has approved as part of the project costs
Can a foreign air carrier be used 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".
Please review RSPA’s Travel on Sponsored Projects policy before making international travel arrangements.
Why can't I charge our federal grant for our Administrative Assistant's time on a project?
In 2 CFR 200, Subpart E, the federal government specifies certain costs that "normally" should be charged only as indirect costs. Administrative assistants fall within this 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. For additional information, see consult the University’s Direct Charging of Administrative Costs policy.
Why do I and anyone else charging salary to my federal award have to sign Effort Reports?
When proposals are submitted, the University is "promising" that, should the sponsor make an award to Notre Dame, certain activities will happen. One of those is the devotion of effort by personnel who are key to the project.
Effort Certification is an internal University process designed to meet regulatory requirements for maintaining records that accurately reflect the work (effort) performed on federally sponsored agreements.
Office of Management and Budget (“OMB”), as part of 2 CFR 200.430 (h) (8) (i), provides standards for documentation of personnel expenses to federally sponsored research projects and the Effort Certification requirement is designed to meet these standards.
An employee’s Effort Report is based on his or her complete payroll distribution for the period being certified. When you sign an Effort Report, you are certifying:
- performance of the work in accordance with your award guidelines
- salary charged to the award is commensurate with the amount of effort expended on the project.
If, during the period covered by the Effort Report, you did not expend the amount of effort anticipated, you must contact Research & Sponsored Programs Accounting to assist you in making an immediate correction to payroll records.
For additional information regarding the effort reporting process, including FAQ’s, please refer to the Effort Reporting section at: http://controller.nd.edu/research-sponsored-programs-accounting/financial-compliance/