Sponsored Accounting Policies


Policy 107 outlines guidance when Participant Costs are applicable to Sponsored Programs. Indirect cost allocations attributable to Participant Costs are the main focus of the policy.

Policy 113 establishes the requirements for recording cost transfers on the financial accounting records of the University. The accounting practices are performed in accordance with internal financial controls and federal regulations.

Policy 119 ensures that revenue from industry sponsored clinical trials at the University is properly recorded. Additionally, it assigns responsibilities associated with the accounting of such trials.

Policy 122 provides guidance regarding Service Centers; including Specialized Service Facilities (SSFs) and Recharge Center Units (RCUs). Additionally, this policy establishes general guidelines for proper rate development and review of federally sponsored awards.

Policy 130 ensures proper accounting of university and externally funded capital equipment. It provides guidance in reporting to sponsoring agencies, planning and formulating budgets, screening for redundant or excessive purchases, and ensuring accuracy of inventory valuation and depreciation expenses. Additionally, this policy ensures that accurate property reports are filed with government and sponsoring agencies at the close of a grant or contract.

Policy 131 provides guidance regarding: 1) effort commitments for sponsored projects, 2) payroll allocations to sponsored projects, 3) certification of effort to sponsored projects; and 4) to conform to OMB Uniform Guidance (2 CFR 200), section 200.430 Compensation for Personal Services and its predecessor, OMB Circular A-21 (for federally sponsored projects issued prior to December 26, 2014) – for which the University follows the prescribed Plan Confirmation method for effort reporting.

Policy 132 provides guidance regarding Cost Sharing; which is the portion of total project costs not paid by the sponsor. Cost Sharing may be required by the funding agency (i.e. Mandatory Cost Sharing) or voluntarily proposed by the University (i.e. Voluntary Committed Cost Sharing).

Policy 143 provides guidance regarding: (1) subrecipient eligibility determinations, (2) assessing and managing risk when passing federal funds to subrecipient organizations, and (3) ongoing subrecipient monitoring activities.

Policy 146 provides guidance related to the monitoring and transfer of unobligated balances in the financial accounting records of the University. This guidance is in accordance with a proper system of internal financial accounting controls, federal regulations, and specific sponsors requirements. Additionally, it ensures that transfers of unobligated balances do not affect award amount, grant and contract revenue, and budgeted indirect revenue collected by the University.

Policy 149 provides guidance related to the timely monitoring, classification and resolution of sponsored projects in the overdraft status.

Policy 158 sets the expectations for proper Financial Reporting and Closeout for sponsored projects. It reinforces the roles and responsibilities of individuals involved in the process, and addresses circumstances that may arise during the award closeout.

Policy 160 provides guidance related to the review and reconciliation of transactions posted to the University’s general ledger. It enhances internal controls, ensures timely adjustments/cost transfers, and prevents overdrafts. Note – the Budget to Actual Reports (BAR) should be used for the review and reconciliation of financial transactions.

All University units with material grant activity are required to have a reserve for actual or potential losses arising from sponsored projects activity. To ensure that activities from sponsored projects have sufficient and sustained reserves, the adequacy of the reserve is evaluated quarterly and, when necessary, adjustments to the reserve are posted.

Policy 172 provides guidance regarding Program Income. Program Income is directly generated by a federally sponsored project occurring during the period of performance of that project. Note – Gross income related to licenses or royalties on patents and copyrights are exempt from this policy.

Policy 179 outlines the appropriate procedures for establishing an Advance (at Risk) Grant Account. This is done in anticipation or the finalization of a sponsored award. The creation of an Advance (at Risk) Account aids in the allocation/ assignment of expenses, and reduces the need for a cost transfer.

Policy 186 provides guidance regarding allocating costs to sponsored projects, thus, conforming to OMB Uniform Guidance (2 CFR 200), section 200.405 Allocable Costs, and its predecessor, OMB Circular A-21 (for federally sponsored projects issued prior to December 26, 2014).

Policy 190 establishes the University’s requirements for small business subcontracting plans. Certain percentages of the direct cost expenditures must be spent with suppliers certified under the following Small Business Administration programs:

  • Small Business Enterprise (SMB or SBE)
  • Small Disadvantaged Business (SDB)
  • Woman-owned Small Business (WOSB or WBE)
  • Historically Underutilized Business Zone (HUBzone)
  • Veteran-owned Small Business (VOSB)
  • Service-disabled Veteran-owned Small Business (SDVOSB)