The Grant, Contract & Gift Accounting Manual (GCG) is intended to assist OSU personnel who work with the financial aspects of sponsored awards; including principal investigators, project directors, accountants, and others.   The GCG policies and procedures apply to all university personnel and are to be used harmoniously with all other OSU Policy & Procedure Manuals when specific procedures are required by a sponsored agreement.   The GCG Manual is maintained by the Office of Post Award Administration.

The Office of Post Award Administration, a division of the Office of Business Affairs, is responsible for the proper administration of sponsored awards to Oregon State University.  The Office of Post Award Administration works with the Office of Sponsored Programs , the sponsoring agency, the principal investigator or project director, and Business Center’s to set up sponsored award  funds, invoice funding entities, monitor fund transactions to ensure that expenditures are allowable and within budget constraints, and close out the fund at project end.

The GCG Manual assists in accomplishing several important tasks:

1. Ensure the proper administration of sponsored agreements.
2. Ensure compliance with all applicable state and federal regulations.
3. Properly identify costs for reporting and Facilities & Administrative (F&A) rate determination.
4. Properly report all funds received by OSU.
5. Provide financial monitoring and reporting for sponsored agreements.
6. Prepare required financial reports and invoices for receipt of sponsored funds.
7. All sponsored agreements are set up in FIS Banner. The degree of deviation allowed by the sponsoring agency varies widely from complete discretion by the project director to requiring agency approval for all changes. The reporting of expenditures also varies in the amount of detail required and the frequency of the reports.

The Office of Post Award Administration staff assists Business Centers in complying with federal guidelines, such as those published by the Office of Management and Budget (OMB), general federal policies regarding the use of funds and proper management procedures, and specific agency rules and regulations.  State regulations, such as rules for purchasing and travel, also must be applied to sponsored award expenditures.  In addition, special conditions incorporated into each award document must be carefully followed.  Additional service information and procedures may be found on the Business Affairs website. 

Corrections, changes, or suggestions for the GCG manual should be communicated to the GCG Manual Coordinator or the Office of Post Award Administration at: 541-737-4711.

In the event of an inconsistency or conflict, applicable law and State Board of Higher Education policies supersede university policies and university policies supersede college, Business Center or lower unit bylaws, policies, or guidelines.

The University reserves the right to add, amend, or revoke any of the contained rules, policies, regulations, and instructions or incorporate additional ones, with or without notice, as circumstances or the good of the university community may require.

Purpose

To describe the processing of pre-award costs, budget changes and no-cost extensions for sponsored programs funded by various federal agencies. To identify the federal agencies who have granted OSU expanded authority.

Applicability

Applies to grants and cooperative agreements, but does not apply to contracts. To determine whether an agreement is a grant, cooperative agreement, or a contract either of these banner screens can be used:

FTMFUND – if the predecessor fund ends in a five, it’s a contract.
FRAGRNT – if grant type box is “C”, it’s a contract. If grant type is a “G”, it’s a grant. If grant type is “A”, it’s a cooperative agreement.

Note: There are other grant types that are not covered under expanded authority.

Background

Several federal agencies have adopted expanded authority policies that waive the normally required sponsor prior approval for specific actions.  Expanded authority is intended to reduce overhead costs, increase research productivity, and reduce paperwork.

Definition

Expanded Authority

The authority granted to OSU that waives certain prior approval requirements by a federal sponsoring agency.   Expanded authority is used only for changes that are necessary for the completion of the project within its original scope and original total budget.

Prior Approval Requirements

A Sponsoring Agency's requirement that the Agency approve changes prior to the change occurring.

Policies and Procedures

Federal agencies that have given expanded authority are:

ONR – Office of Naval Research (except no-cost extensions)

NASA – National Aeronautics & Space Administration

NSF – National Science Foundation

USDA/NIFA (formerly CSREES)  Note: Expanded Authority has been delegated for NIFA (formerly CSREES) only, not all branches of USDA.)

US-Ed – US Dept of Education

NIH/PHS – National Institutes of Health/Public Health Service

NOAA/US Dept of Commerce – Nat’l. Oceanic & Atmospheric Administration  

Note: Expanded Authority has been delegated for NOAA only, not all branches of US-Dept. of Commerce. No rebudgeting direct for F&A or vice versa, unless noted in special terms and conditions.

DOE – US Dept of Energy

EPA – Environmental Protection Agency

ARO – Army Research Office

DOT - Department of Transportation  

AID – Agency for International Development

BUDGET CHANGES

A reallocation of budget line items may be requested.  For agencies who have granted expanded authority, such changes are accomplished by a budget JV using journal type 1PBB - include proper justification in the text field; the Office of Post Award Administration (OPAA) must approve the JV. 

PRE-AWARD COSTS

Normally, expenditures may not be charged against sponsored programs before the effective date of a sponsored agreement. However, some federal agencies allow requests for pre-award expenditures to be reviewed and approved within OSU via expanded authority.

NSF, NASA, USDA-NIFA (formerly CSREES), NOAA, NIH/PHS, AID, ARO,DOE, DOT, EPA, US-ED and ONR: Approval may be granted for expenditure of funds up to 90 days prior to the expected start date of a new grant or cooperative agreement. Advance funding must be necessary for the effective and economical conduct of the project.  Pre-award costs will not be approved unless a Department Head/Chair or a Dean/Director guarantees to reimburse the university in the event the grant or cooperative agreement is not received.  Request pre-award costs using Pre-Award Cost form. 

ALL OTHER AGENCIES OR SPONSORS: OSU is not authorized to approve pre-award costs for other agencies. However, it may be possible for OPAA to set up a “pending index” for awards anticipated to be funded, but for which the award document has not yet been received or fully executed. See GCG 105: Cost Accounting Standard Guidelines, #4 in Grants & Contracts section.

NO-COST EXTENSIONS

NSF, NASA, USDA-NIFA (formerly CSREES), NOAA, NIH/PHS, AID, ARO, DOE, DOT, EPA and US-ED: OSU, via expanded authority approve a one-time no-cost extension of up to one year beyond the original expiration date.  The request must be submitted to OPAA at least 30 days prior to the expiration date of the project.  OPAA must notify the agency at least 10 days prior to the expiration date of the project. Review of request will consider summary of progress, estimate of funds remaining, and plans for the completion of the project. Complete the OPAS/No-Cost Extension form and submit to the OPAA Grant Accountant responsible for the specific agency. 

Examples of when such an extension may be requested are as follows:

1. additional time is required to assure completion of the original approved objectives; or
2. continuity of grant support is required while a competing application is under review; or
3.  extension is necessary to permit an orderly phase out of a project that will not receive continued support. The fact that funds remain in the grant is not in itself justification for a no-cost extension.

Specific for: USDA - NIFA (formerly CSREES): up to a maximum potential award period not to exceed five years. The award period will commence as of the effective date cited in the grant; however, if OSU has elected to charge allowable pre-award costs under the grant, the award period will commence, for the purpose of determining the beginning of the maximum potential five year award period, on the date the first pre-award cost is incurred.

Specific for ONR: Complete the OPAS/No-Cost Extension form and forward to the OPAA Grant Accountant for review and processing.  Upon approval, the Assistant Director of Business Affairs/OPAA will forward the request to ONR via e-mail.

No cost extensions cannot be processed under expanded authority if the award is past the end date.  The OPAS/No-Cost Extension form must be completed and the request for extension must be made by the PI, in writing, on letterhead. The letter should be signed by the PI and include a blank line so that it can be countersigned by the Assistant Director of Business Affairs/OPAA.  OPAA will forward to the sponsoring agency.

EXAMPLES OF CHANGES NOT COVERED UNDER EXPANDED AUTHORITY (written agency approval is required to do any of the following):

• Changes to student support 
• subcontracting any portion of the scope of work
• Construction   
• Change in scope of work
• increasing funding levels
• Change of PI - See website for Sponsored Programs for form.  

All persons associated with a sponsored project are responsible for knowing the applicable regulations, principles, standards and policies.  These may include federal polices as well as sponsor, State of Oregon, Oregon University System (OUS), and Oregon State University (OSU) guidelines.   These include, but are not limited to, the following:

104-01 Office of Management & Budgets (OMB) Circular A-21 Cost Principles for Educational Institutions 

This Circular establishes principles for determining costs applicable to grants, contracts, and other agreements with educational institutions. The principles deal with the subject of cost determination, and make no attempt to identify the circumstances or dictate the extent of agency and institutional participation in the financing of a particular project. The principles are designed to provide that the Federal Government bear its fair share of total costs, determined in accordance with generally accepted accounting principles, except where restricted or prohibited by law. Agencies are not expected to place additional restrictions on individual items of cost. See OMB Circular A-21 (Adobe .pdf document) on Cost Principles for Educational Institutions.

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104-02 OMB Circular A-110 Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations 

This Circular sets forth standards for obtaining consistency and uniformity among Federal agencies in the administration of grants and cooperative agreements with institutions of higher education, hospitals, and other non-profit organizations. For additional guidelines see OMB Circular A-110 on Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education

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104-03 OMB Circular A-133 Audit of Institutions of Higher Education and Other Non-Profit Organizations 

This Circular is issued pursuant to the Single Audit Act of 1984, P.L. 98-502, and the Single Audit Act Amendments of 1996, P.L. 104-156. It sets forth standards for obtaining consistency and uniformity among Federal agencies for the audit of states, local governments, and non-profit organizations expending Federal awards. For additional guidelines see OMB Circular A-133 on Audits of States, Local Governments, and Non-Profit Organizations 

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104-04 Federal Acquisition Regulations (FAR)

The Federal Acquisition Regulations system is established for the codification and publication of uniform policies and procedures for acquisition by all executive agencies. FAR applies to contracts.

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104-05 OREGON UNIVERSITY SYSTEM-FINANCIAL ADMINISTRATION STANDARD OPERATING MANUAL (FASOM)

FASOM covers basic accounting principles of OUS and is now being integrated into the OUS Fiscal Policy manual.

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104-06 OSU FISCAL OPERATIONS MANUAL (FIS)

The FIS Manual provides the user with policies and procedures applicable to accounting-related transactions at the university. The fiscal policies and procedures apply to all university departments.

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104-07 COST ACCOUNTING STANDARDS BOARD (CASB)

The CASB was created by Congress to establish accounting rules and regulations. The Cost Accounting Standards (CAS) Handbook may be obtained by contacting the Office of Post Award Administration at 737-4711.  The CAS most applicable to OSU are:

CAS 501 – Consistency in Estimating, Accumulating, and Reporting Costs by Educational Institutions.
This standard requires that cost accounting practices used for estimating costs in proposals be consistent with the cost accounting practices used in accumulating (recording) and reporting costs. The standard is designed to provide a basis to compare proposal cost estimates with the actual costs. In its simplest terms, the standard requires that if costs are included in the project proposal, they must be accounted for as project costs; this includes cost sharing. When salaries are charged, effort reports must tie with accounting records (including any cost transfers), with proposal budgets, and with all progress reports to the sponsor.

CAS 502 – Consistency in Allocating Costs Incurred for the same Purpose by Educational Institutions.
This standard deals with consistency in accumulating like costs incurred for the same purpose. It requires that each type of cost be allocated only once, and on only one basis to any contract or other cost objective. The institution must identify which costs are charged (1) only as direct, (2) only as indirect, or (3) both as direct and indirect. In its simplest terms, the standard requires that cost coding must consistently identify like costs in like circumstances as always direct or always indirect. If a contract is charged directly for a cost, the same type of costs should not be in the F&A rate, and vice versa.

CAS 505 – Accounting for Unallowable Costs – Educational Institutions.
This standard contains guidelines on consistency in identifying unallowable costs and how they are treated within the cost accounting system. The standard does not provide additional guidance on what is unallowable; educational institutions will still follow OMB Circular A-21. In its simplest terms, the standard requires that costs expressly unallowable under OMB Circular A-21 or mutually agreed to be unallowable under terms of the agreement must be identified and excluded from any billing, claim, application, or proposal applicable to a sponsored agreement. Detailed records should establish and maintain visibility of identified unallowables, including allocation and cost accounting treatments.

CAS 506 – Cost Accounting Period – Educational Institutions.
This standard requires that the cost accounting period and all costing information (both direct and indirect) is based on the same period as the institution’s fiscal year. For OSU that period is July 1 to June 30.

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Cross Reference

See GCG 407: Reference Websites for specific agency information and other website references.

Applicability 

Persons in Oregon State University (OSU) departments who work with financial aspects of sponsored projects – principal investigators, project directors, accountants, and others. 

Procedure 

All Funds:

1. Deposit all income in the same index that is used to accumulate the related expenses of the activity.
2. Charge all fund raising and public relations costs to State funded indexes identified as “Development”.
3. Keep track of all “Lobbying” costs. All trips to Washington, DC are suspect.
4. Use the correct Account Code to record expenditures.
5. Move State budget to index where costs are incurred; don’t move cost to budget.
6. Record cost sharing or matching expenditures in the cost share index associated with the project.
7. Complete Space Inventories accurately and promptly.
8. Cooperate in completing Equipment Inventories accurately and promptly.

Grants and Contracts:

1. Budget for all project costs in proposals. See outlined instructions listed in the Proposal Process webpage on the Research Office Website.
2. Budget for and pay GRA tuition/fees on grants (unless specifically unallowed by the sponsor).
3. Request a 90-day OPAS pre-award through the Office of Post Award Administration in those cases where justification exists for starting the project prior to the award date.
4. If agency does not allow pre-award costs, submit a pre-award memo to the Office of Post Award Administration to establish a pending index/fund to account for costs incurred if official award document has not been received.  See GCG 103: Expanded Authority -  Budget Changes, Pre-Award Costs & No-Cost Extensions.
5. Read the award documents so you are aware of all restrictions and reporting requirements/deadlines
6. Pay all allocable project costs on applicable grant index.
7. Make any cost transfers timely and before the project end date. Labor Distribution forms and JV’s both require justification if transfers are retroactive. See GCG 209-08: Cost Transfers/Redistribution. 
8. Prior to submitting subcontractor charges for payment, review invoices for incurred costs in relation to approved project activity and progress.    
9. Initiate project budget changes if necessary and when the agency allows. Use JV journal type “1PBB”. Include proper justification in text of JV.
10. Complete quarterly Effort Reports (PAR forms) required under OMB Circular A-21. Ensure that any change in effort is reflected and is processed through payroll on a revised Labor Distribution form.
11. Complete all progress and final reports called for in the award documents before required due dates.
12. Request a no-cost extension either using OPAS system through the Office of Post Award Administration or directly to the agency if the project cannot be completed by the current end date.  Requests need to be made 45 days prior to end date.

All Funds:

1. Do not promise to make donations – either from State, Federal or sponsored funds. Donations are unallowable.
2. Do not charge proposal preparation costs to grant indexes. Such costs are departmental costs.

Grants and Contracts:

1. Do not pay for administrative support (e.g. clerical, accounting) directly on a grant, unless included as a specific line item in the proposal budget approved by the sponsoring agency. Administrative support refers to type of duties regardless of pay account code.
2. Do not charge telephone unit or line costs to a grant. Only long distance costs are allowable as a direct cost.
3. Do not pay utility costs on grant funds unless the project is at an off-campus location and utility costs are specifically budgeted.
4. Do not pay subcontract invoices unless budgeted and the researcher has assured that the subcontractor is providing the project deliverables as defined in the scope of work.
5. Do not pay for subscriptions or memberships on grant indexes. Unless they are directly related to the project.
6. Do not make expenditures that are not included in the approved budget. Be particularly aware of equipment, international travel, subcontracts and participant support/stipend costs.

Background

There are four Cost Accounting Standards that govern expenditures for educational institutions, see GCG 105: Cost Accounting Standard Guidelines. Some agencies have provided a waiver of prior approval requirements; see GCG 103: Expanded Authority.

Policy

Revisions are permitted only if necessary for the completion of the project within its original scope and budget.  Per agency guidelines and award agreements, there may be other limitations to reallocation of budget line items.

Expense Approvals on Restricted Funds

Expenses  that are charged to restricted  funds are  routed electronically to the appropriate Business Center  for review and approval prior to going to Business Affairs Payables for  check generation.  Any expense $300,000 and over will route electronically to Business Affairs for final review and approval before check generation. 

Fixed Asset Approvals

Prior to purchasing a fixed asset (item over $5,000 which must be recorded in the university's inventory), unit personnel are required to get purchase approval by preparing a departmental requisition, obtaining necessary approvals, and sending the document to the appropriate Business Center.  Once the expenditure is approved by the Business Center (up to $24,999) or PaCS ($25,000 or over), a purchase order can be issued for the asset. (Purchase Orders on restricted funds are routed through an OPAA approval queue.) Payment for the item can be made against the purchase order by processing an invoice for the fixed asset in Banner FIS.

Fixed Asset invoices are also routed to the Office of Post Award Administration and Property Administration for approval prior to final processing by Business Affairs Payables. When a capital asset is paid for in Banner FIS using commodity level accounting and account code 40XXX it is required that inventory information be entered into the text screen.

Additional Information

See FIS 1108: Approval Routing for additional information on Approvals.

Background Information

There are four Cost Accounting Standards that govern expenditures for educational institutions, see GCG 105: Cost Accounting Standard Guidelines. Some entities have provided a waiver of prior approval requirements; see GCG 103: Expanded Authority.

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Policy
204-01:  Costs

All allowable costs will be determined by OMB Circulars A-21, A-110, Federal Acquisition Regulations, and/or by the granting entity through grant manuals or award terms and conditions.

For Federally Sponsored awards, allowable costs generally fall within these guidelines:

1. Costs must be reasonable. This is defined as the action that a prudent person would take under the circumstances.
2. Costs must be allocable to federally sponsored agreements under the principles and methods described in OMB A-21. (See OMB Circular A-21; Unallowable Costs.)
3. Costs must be given consistent treatment through application of Generally Accepted Accounting Principles (GAAP) appropriate to the circumstances as dictated by Cost Accounting Standards (CAS). This includes the use of account codes for cost classification.
4. Costs must conform to any limitations or exclusions set forth in OMB Circular A-21 or in the sponsored agreement as to types or amounts of cost items.

Under CAS these same principals are applied to all sponsored awards received by OSU, regardless of funding source.

All sponsored projects are set up on a budget. The degree of deviation allowed by the granting agency varies widely from complete discretion by the project director to requiring agency approval for all changes. The reporting of expenditures also varies in the amount of detail required and the frequency of the reports.

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204-02:  Cost Classification: Assigning Account Codes

The administration of a contract, grant or cooperative agreement project involves identifying all costs associated with it. Cost information is needed both to manage the internal affairs of the university and to satisfy external requirements. An account code is assigned to each cost to classify the expenditure according to goods or services received.  Each department/Business Center/PI is encouraged to use the FIS Banner system to record encumbrances and to stay current with commitments made during the project.  See GCG 205: Expenditure Account Codes.

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204-03:  Allowable Direct Costs

Direct costs are expenditures associated with grants, contracts, and cooperative agreements that are necessary for and can be identified with the performance of a specific sponsored project.  Direct costs of a sponsored project include all personnel costs charged to the project; applicable payroll assessments, graduate tuition remissions, expenditures for supplies and equipment, travel expenses, printing, other service department charges, and any other expenses specifically identified with the project.

Principal Investigators and Business Center accountants should refer to the award document for requirements or restrictions specific to the project. Contact the Office of Post Award Administration for assistance with specific questions.

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204-04:  Unallowable Costs

Unallowable functions, such as lobbying, public relations, and fund raising, are groups of costs that due to the nature of the function will make the expenditure unallowable.  For example, salaries and wages are generally allowable costs; however, those same salaries and wages incurred for the benefit of a fundraiser are unallowable.  Therefore, the function makes the expenditure unallowable.

Some unallowable costs, such as alcoholic beverages, are types of expenditures that are specifically unallowable by law, regulations and/or contract terms.  See     OMB Circular A-21 section J. Both unallowable costs and expenses connected with unallowable functions must not be direct charged to sponsored agreements.

Other costs, such as utilities and building maintenance are unallowable as a direct cost unless approved in the proposal process and by the sponsor. See GCG 205: Expenditure Account Codes, for guidance.

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204-05:  Facilities and Administrative Costs (Formerly Indirect Costs)

Facilities and Administrative (F&A) costs are expenditures associated with a grant, contract, or cooperative agreement that cannot be directly charged to nor specifically identified with individual sponsored projects. These costs include maintenance of physical facilities, library services, administrative services, and departmental administration. In general, F&A costs involve expenditures necessary for the development and maintenance of an environment conducive to research and other sponsored projects.

Most grants and contracts provide for the recovery of F&A costs incurred in their executions and management. The recovery is based upon negotiated rates and assessed to individual projects on a percentage basis. The rates for Oregon State University are negotiated with the U.S. Department of Health and Human Services, Division of Cost Allocation (DHHS-DCA). The negotiation is based on a review of the university’s costs and assessment of the reasonableness of the charges.

In most cases, F&A costs for a sponsored project are calculated by multiplying the approved F&A rate and the Modified Total Direct Cost (MTDC) paid on the award. MTDC is determined by subtracting tuition remission (1095x); equipment/capital expenditures (4xxxx); subawards over $25,000 (399xx); participant costs (5xxxx & 2863x) and other excluded items from the total direct costs (salaries and wages, fringe benefits, materials and supplies, services, travel, and subawards) posted on the sponsored project account. Account Code 70005 is used to record the recovery of F&A costs (formerly indirect costs).

• F&A cost is charged based upon the rate and base in the approved award, up to the federally negotiated rate.
• Slight F&A cost adjustments may be made manually by the Office of Post Award Administration during the award closeout process.

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Additional Information

The current F&A rates are available at the Sponsored Programs website.

205-01:  1XXXX — Salaries and Wages

This group of account codes applies to all payroll expenditures in each personnel category. Payroll is to be charged to a research fund only for the award period. Salaries and wages for project personnel are accounted for on a fiscal year basis according to the percentage of an individual’s effort that is allocable to and budgeted in the sponsored project.

• Payroll is not to be charged to a sponsored project index after the award’s expiration date.
• Because of the complexities and time involved in payroll adjustments, it is very important that payroll be placed on the proper indexes initially. Payroll distribution should be reviewed periodically and adjusted for effort expended on the project. This review must be completed no less frequently than quarterly in conjunction with PAR form certification.
• NSF 2/9 Rule – Allows faculty to budget only two months’ salary in the summer for those faculty who have nine-month academic year appointments.
• Salary Caps – The National Institute of Health has a salary cap, an amount equal to Federal Executive Pay Level I. Department of Defense (DOD) also imposes salary caps for certain programs. It is very important to review the guidelines of the particular granting agency.
• Communication Allowance– Per OMB Circular A-21, communication access costs are considered part of indirect cost and are not an allowable direct cost on grants and contracts; this includes federal and match state-wide funds. This allowance is posted as account code 10240 Unclassified Perquisites or 10440 Classified Perquisites. See FIS manual 1402-15 or this GCG manual 205-07 for more information.

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205-02:  Graduate Research Assistant (GRA) and Graduate Teaching Assistant (GTA) Salaries

GRA and GTA salaries may be paid on four different account codes.  The proper account code to be used depends on whether or not the sponsor pays tuition remission and if the responsibilities are teaching (GTA) or research (GRA).

GRA account codes are 10630 and 10632.  If the sponsor pays tuition remission, 10630 is used.  If the sponsor does not pay tuition remission, 10632 is used because the tuition must be subsidized by the university.  If the sponsor does not pay tuition remission, it is charged to the tuition remission Cost Share index that has been set up for each department.

GTA account codes are 10620 and 10622. If the sponsor pays tuition remission, 10620 is used.  If the sponsor does not pay tuition remission, 10622 is used because the tuition must be subsidized by the university.  If the sponsor does not pay tuition remission, the tuition is charged to the tuition remission Cost Share index that has been set up for each department.

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205-03:  1090X— Other Payroll Expenses (OPE)

OPE is payroll and personnel assessment expenditures such as Federal Insurance Contributions Act (FICA), Public Employees’ Retirement System (PERS); State Accident Insurance Fund (SAIF); Medical, Dental, and Life Insurance; and assessments from the Personnel Division Workers’ Compensation Board and Employee Relations Board. Also commonly known as fringe benefits.

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205-04:  10640 and 10941 - Graduate Assistant Perquisites and Health Insurance Benefit

OSU provides Graduate Assistants (teaching and research) a health insurance benefit as part of their compensation package, which should be paid on account code 10941.  Additionally, account code 10640 should be used to record other compensation (such as meals or lodging allowances) which Graduate Assistants may receive.  For additional information see the Graduate Employee Contract Information web page and the OSU Graduate School home page.  Questions about how this policy relates to sponsored research should be emailed to the Office of Sponsored Programs and Research Compliance.

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205-05:  1095X—GRA Tuition Remission

These codes are used to record expenditures for all graduate research assistants’ and graduate teaching assistants’ tuition remission costs. Allocation is based on salary distribution for the academic term. Tuition remission does not include other institutional fees, only instruction tuition. See Graduate School website for more information regarding GRA appointments.

• The fund to which tuition remission is charged is not an option of the department. The tuition must be charged to the salary index, unless the charge is not allowed by the sponsor. In that case, the tuition must be charged to the department’s cost share index.
• If salary is prorated between indexes, the tuition is also prorated. Tuition remission charges are calculated using default pay salary indexes for the academic term.
• If GRA payroll is transferred from one index to another. Payroll will make proper corrections.

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205-06:  20XXX, 21XXX—Supplies, Minor Equipment

These account codes apply to expenditures for acquisition of materials and supplies.

• Generally, all supplies, equipment, and services must be ordered and received before the expiration date of the award and used in the course of the project. Final vendor invoices for payment of these goods should be processed through FIS Banner and Accounts Payable immediately upon receipt in order to meet financial reporting requirements.

• Account codes 20200 through 20216 should be used for minor equipment purchases. Minor equipment includes items, which will not be consumed (supplies) and do not meet the capitalized equipment (40101) definition. Purchases made toward the end of the award will be carefully reviewed.

• Subscriptions and Publications 201XX

For a subscription or publication cost to be a direct cost and chargeable to a grant, contract or other direct program such as instruction or public service depends on the circumstances.  The alternative is to treat the expense as indirect and pay the cost on departmental funds.

To be a direct expense, the subscription or publication must be necessary toward meeting the goals or functions of the program.  The material contained in the publications is to be used in the project being performed as compared to professional development of a person’s proficiency or keeping current in his/her field.

OMB Circular A-21 requires that all expenses charged to grants and contracts be identified with the sponsored work.  When the cost of a subscription or publication is deemed necessary as a direct cost to a grant or contract, the justification must be in the text file of the Banner invoice or in letter format to the Office of Post Award Administration, the Banner invoice text file will reference the letter.  Each subscription and publication request must be individually approved.

Unique Electronic Items
The purchase of personal digital assistants, laptop computers, watches, digital cameras, video equipment and other unique electronic items with sponsored project funds must be in conformance with OMB Circular A-21, part D.1.

• must be specifically identifiable with a particular sponsored project
• must be properly justified in the text of the invoice payment in Banner as to the direct relationship to the research project
• ownership of these items will remain with OSU
• these items must be maintained on the department’s minor equipment/supplies inventory
• appropriate loan forms must be completed if item is removed from OSU locations.

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205-07:  220XX, 225XX—Communications and Shipping

These account codes are used for expenses arising from the use of telephone, mail, freight, and express services.

Per OMB Circular A-21, communication access costs are considered part of indirect cost and are not an allowable direct cost on grants and contracts; this includes federal and match state-wide funds. Therefore, any charges to research projects (sponsored, AES-funded, or FRL-funded) or other sponsored activities (sponsored or Extension-funded) must be approved in advance. Request for an unlike circumstance, such as remote location (field study), or emergency access must be made to and approved in writing by the Assistant Director of Business Affairs, Office of Post Award Administration (OPAA). The Communication Allowance is not an option available as a direct charge.

Requests for an unlike circumstance should be supported as follows:

• Costs should be identified in approved proposal
• Itemized bill needs to be made available for audit purposes
• Budget on 22013 for cell phones

Direct charge will only be allowed for an OSU provided cell phone purchased through OSU Telecommunications. If this option is not available, Telecommunications and PaCS must be involved in the selection and contract acceptance process.

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205-08:  230XX, 233XX — Utilities & Waste Disposal

These account codes are used in classifying expenditures for electrical usage, gas, sewage charges, steam, hogged fuel (wood chips), fuel oil, and water.

• This type of expense is allowed on sponsored awards for research at off-campus locations only and only if indicated as a line item in the budget. These expenses are included in F&A cost for on-campus activities.
• Occasionally there may be a project that requires an above normal use of utilities at an on-campus site (such as the wave tank). This additional cost is allowable as a direct charge if justified in the proposal and approved by the sponsor.
• Charges for radioactive waste disposal are allowed, if waste is generated by the project and specifically budgeted for in the proposal.

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205-09:  235XX — Maintenance and Repairs

These account codes apply to expenditures for maintenance and repairs of buildings, grounds, and equipment. They are intended for ordinary expenses of a recurring nature, including maintenance contracts.  Outside labor charges for maintenance and repair services are included.

• Building or grounds maintenance and repairs should not be charged to sponsored awards. (These expenses are included in the F&A rate).
• Repairs to equipment that do not increase the original value of the equipment by more than $5000 nor extend the estimated useful life of the equipment will be recorded as “Equipment Maintenance and Repairs” and not as “Equipment”, regardless of dollar amount.

Equipment maintenance costs are allowable as a direct cost for those items that are used in the project.

In most cases, any item that appears to be general purpose or that will outlast the project cannot be direct charged.

Maintenance Contracts

Equipment service contracts can be paid with grant funds if the equipment was purchased with that grant’s funds (or in the case of continuing grants from the same agency). The service maintenance contract cannot be for a time period past the end date of the agreement.

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205-10:  240XX — Rentals and Leases

These account codes record payments for rental or lease of equipment, land, and buildings, except equipment acquired on a lease-purchase arrangement.  To direct charge to a sponsored agreement, these costs should be identified in the proposal.  Building and land rentals are excluded from modified total direct costs and facilities and administrative costs are not calculated on these costs.

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205-11:  245XX—Fees and Services

These account codes record expenditures for professional fees, e.g., consulting and legal fees, services rendered by commercial firms; service charges by institutional service departments; and fees assessed by other state agencies.

• Generally, all services must be performed within the award period.  Journal vouchers must reflect the date that the service was performed.

Exception: National Science Foundation (NSF) and National Oceanic and Atmospheric Administration (NOAA) grants allow for printing of technical reports after the expiration date. These printing estimates should be encumbered through the FIS Banner Purchase Order encumbrance system before the expiration date of the grant.

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205-12:  24503--Computer Use Charges

Direct charges on grants and contracts must meet the following criteria:

1. Charge is for services over and above that provided to all faculty and staff; i.e. email, communications, word processing, spreadsheets and other common functions.
2. The charges are from a unit which distributes costs to all users (not just grants and contracts) AND the distribution method has been approved by Business Affairs and listed as an approved fee in either the University Fee Book or OSU Internal Fee Book.
3. Costs included in this category include network, server and computer/software maintenance charges.

Computer operations that do not meet the criteria above are included in the Facilities and Administrative (F&A) rate proposal and are charged to the grant and contract in the F&A cost rate.

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205-13:  2860X —  OSU Sponsored Conference Expenses

These accounts should be used for workshop activity on workshop and restricted funds. This includes rental of the facility (28606). These charges should be in the approved budget.

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205-14:  2861X — 28612 Hosting

28610 Entertainment and 28611 Interdepartmental Refreshment costs should not be charged on sponsored project funds. 28612 Hosting Groups and Guests, meals/expenditures for hosting official guests can be directly charged to sponsored project funds when hosting a speaker or other activity appropriate to the award.

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205-15:  28613 — Public Relations Activity

Public relations and fundraising activity costs should not be placed on sponsored project funds.

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205-16:  2863X — Non-OUS-Participant Support & Post Doc Fellowships

Support for non-OUS students and participants. Support could include tuition, stipends, room and board, book allowances, etc.

See FIS 410-32 Participant Support Costs for additional information or clarification.

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205-17:  289XX— Memberships and Dues

Normally, memberships are considered to be institutional and not individual (personal).

To be a direct expense, the membership must be necessary toward the goals or functions of the program.

OMB Circular A-21 requires that all expenses charged to grants and contracts be identified with the sponsored work. Justification must be in the text file of the Banner invoice or in letter format to the Office of Post Award Administration; the Banner invoice text will reference the letter.

For additional information on Memberships and Subscriptions view the Fiscal Operations Manual at Section 400: Expenditures:

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205-18:  39XXX—Travel

These codes apply to transportation, lodging, meals, and incidental expenses incurred by persons traveling on behalf of the Oregon University System. There are four categories of travel expenses: In-State, Out-of-State, Foreign, and Group.

For each category of travel:

• Use in-state codes for travel TO and WITHIN Oregon.
• Use employee codes for travel by OUS employees, including students traveling as employees;
• Use non-employee codes for employees of other state agencies, students who are not  employees, and all other non-employees.
• Use 55XXX account code series for sponsored student (participant trainee) travel costs.
• All international travel using federal funds must be by U.S. flag air carriers if service by such a carrier is available. Cost is not a factor in determining availability. The first or last leg of travel from or to the U.S. must be by a U.S. flag air carrier in almost all instances. Business class is permitted. See GCG 209-09 Fly America Act (Federally Funded Air Travel).
• Travel fares charged to a federal project must be for less than first-class air accommodations.
• Many subcontracts, e.g., University of Washington, Jet Propulsion Laboratory (JPL), National Renewable Energy Labs (NREL), etc., are funded with federal money, and all federal regulations must be followed. If unsure of the prime-funding source, check with the Office of Post Award Administration before making travel arrangements.
• Some agencies require prior approval before use of funds for international travel.
• A Foreign Travel Authorization form is required for all international travel (including non-employees) using restricted grant, contract funds before making travel arrangements.

Domestic Travel – Travel authorizations are subject to departmental/unit policy.

Evidence of travel status must be provided:

• Regardless of the funding source or basis of reimbursement
• Normally in the form of lodging receipts
• Vehicle rental, local transportation, meal receipts, or other receipts showing the travel location may be used.

Contracts and awards that require receipts to be submitted with the reimbursement request:

• The Office of Post Award Administration will assist departments in identifying the contract or other awards by noting the requirement on the original Award Information Sheet.
• Departments are responsible for including receipts in their reimbursement.
• A cost overrun will be charged to the department for any travel that is billed to  the sponsor and subsequently disallowed due to lack of receipts or documentation for the reimbursement.

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205-19:  39492 – In-State Sponsor Workshop Speaker Travel – No Indirect Cost

Travel expenses incurred when an agency, that doesn't follow F & A on speaker travel, sponsors a workshop and restricted funds are used to pay these travel expenses. There is no indirect cost charged against this account code. An example would be when NSF sponsors a workshop and pays travel expenses for the speaker.

Group travel is limited to field trip travel where students and advisors are present.

Passport Fees (24999)
The only passport fees allowed to be paid on restricted funds are for those directly connected with the sponsored projects.

VISA (24999)
Visa fees will be paid if related to project and required by project. Associated travel to obtain Visa is not allowed.

Note: Specific contracts or other awards may require the submission of receipts.  The Office of Post Award Administration will assist departments in identifying these contracts or awards by noting the requirement on the original Award Information Sheet.  Departments will be held responsible for receipts that are not submitted with reimbursements or for reimbursements that were done using incorrect methods.  A cost overrun to the department will be prepared for any travel that is billed to the contractor and subsequently disallowed due to lack of receipts or documentation for the reimbursement.  For additional information regarding travel see the Business Affairs Travel Policy & Procedure Manual.

Travel reimbursed by a source other than the awarding entity.

When travel expenses are reimbursed by an outside entity other than the awarding entity, the expense must be moved to the department’s general fund, by journal voucher. The reimbursement may then be deposited as a reduction of expense in the department’s general fund.

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205-20:  39XXX—Subcontracts

These are subaward agreements written by OSU to another entity to perform a portion of the sponsored agreement. These account codes are only allowed on restricted grant, contract or cooperative agreement funds. See GCG 206: Subcontracts for further details on subawards.

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205-21:  401XX, 40201, 40104—Equipment, Vessels, Vehicles

These codes are used to record expenses related to the purchase and/or construction of equipment, vessels and vehicles.  Equipment is tangible, personal property that is not consumed in the normal course of business; has a unit value of $5,000 or more; and has a useful life of more than one year.  The State of Oregon specifically excludes software from the equipment category. Refer to Property Management Handbook for specific definitions of equipment and components.

• Many awards require prior agency approval before purchase of equipment. Watch this area closely.
• Read equipment clauses in awards carefully:
• Sponsoring agency may have ownership rights to purchased equipment or equipment upgrades.

1. Disposition of equipment becomes complicated when there is federal ownership and multiple sources of funds have been used to purchase the equipment. Cost sharing the purchase or upgrade of equipment between different sponsoring agencies is discouraged unless specifically approved by the sponsoring agency.
2. Some sponsors often require submission of copies of invoices for equipment purchases to the agency at the time of purchase.

• Any purchase on grant or contract funds identified as a capital fixed asset; using 401XX, 40201, or 40104 must be approved by the Office of Post Award Administration prior to placing order.

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205-22:  40299—40319 Real Property, Land

Land (real property) cannot be purchased on restricted funds without specific sponsor approval.

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205-23:  405XX Buildings

Buildings cannot be purchased or constructed on restricted funds without specific sponsor approval. If approval is given to construct a building, an 8XXXX plant fund will be established to record the costs.

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205-24:  55XXX—OUS Participant/Student Support

These account codes apply to expenses related to participant support and sponsored fellowships.   These account codes cannot be used with Endowment funds, Service Department funds, or any General State funds.

• These codes are used to classify expenditures from funds received to support students engaged in training or research in a specific field or program. Typical expenses are stipends, dependency allowances, tuition, fees, travel, books, materials, and other subsistence needs. There must be participant support line-item(s) in the budget to use these account codes.

See FIS 410-32 Participant Support Costs for additional information or clarification.

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Additional Information

See GCG 208: Participant Support Costs for additional processing information.

Background

Oregon State University (OSU) annually receives over 200 million dollars in support of research and sponsored projects.  Most of the funds come from federal agencies and OSU passes through a portion of the sponsored award to another entity for the purpose of completing  programmatic effort on the project. The legal relationship is between the prime recipient (OSU) and the subrecipient.  It is important to maintain this relationship  to avoid conflicts of interest  between the sponsor and subrecipient.  All project administrative matters of the subaward must go through OSU.  See Conflict of Interest Policy

Those entities consist of other universities, private companies and, occasionally, other federal agencies that will assist and/or collaborate with the OSU principal investigators on sponsored projects.  The agreements with other entities are called subawards and are written by the Office of Sponsored Programs – Research Contracts.  The terms and conditions of a sponsored award received by OSU in support of a project are incorporated into the subaward.

There is a series of account codes assigned for tracking of budget, revenue and expenditures for individual subawards. This series allows for tracking of up to fifteen different subawards per grant fund. The list of account codes and their descriptions can be found on the OUS Fiscal Policy Manual,

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206-01:  Subaward vs. Procurement

To determine whether a sponsored award is a procurement or subaward, see the Sponsored Programs website for guidelines.

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206-02:  Managing Subcontracts

Responsibility of PI, Business Center

• Notify the university Office of Sponsored Programs – Research Contracts when a subaward or amendment needs to be written.
• Provide an adequately prepared statement of work describing how the prime recipient (OSU) expects the subrecipient to accomplish the tasks.
• Review invoices, approve for payment and input into Banner. If the encumbrance number is not referenced when paying invoices on a subaward, Business Centers will need to make manual encumbrance corrections.
• Communicate with Key Personnel listed in subaward.
• Ensure all reporting obligations are met.
• Verify that the subaward scope of work has been completed.

To communicate with OPAA on any issues of non-compliance or if the Prime PI (OSU) is withholding payment for any reason.

Responsibility of Subrecipient

•  Be aware of all contract terms and conditions; OMB Circulars A-110, A-21, and A-133 are the guides for flow down from a federal assistance award. Commercial sub-recipients also need to be aware of Federal Acquisition Regulations subpart 31.2 –Contracts with Commercial Organizations.
• Submit invoices with signed certification, detailed by budget line item, to the university no more frequently than monthly, but at least quarterly.
• If subrecipient has committed to cost share, subrecipient shall document the cost share for the period with each invoice.
•  Maintain acceptable financial systems and accurate records that identify  the award’s expenditures.  
• Maintain effective control over and accountability for all funds, property, and other assets.
• Maintain consistency with applicable cost principles.
• Communicate with the Principal Investigator at Oregon State University.
• Ensure all reporting requirements are met.
• Submit final invoice and closeout documentation after award termination date or as otherwise noted in agreement.
• To comply with record and retention requirements.
• To provide backup documentation, when requested, for all costs.

Responsibility of the Office of Post Award Administration

• Set up subaward to create a file in Nolij.  
• Encumber subcontract in Banner and verify budget dollars. Notify Business Center accounting staff and OPAA grant accountant, if any adjustments are necessary.
•  Review invoices prior to sending to Business Center, and monitor subawards to ensure invoices are tied to general encumbrance, appropriate account codes were used for payment, equipment purchased only if allowed on subaward , monitor reporting of cost share, and verify correct indirect cost rate used.
• Send closeout letters to subrecipient   prior to award termination date, and begin the closeout process.

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206-03:  Property Purchased by Subrecipients

Subawards are usually predicated on the prime award and a copy of the prime is typically attached to the subaward agreement.  Typically the terms of the prime award flow down to the subrecipient.  If there are unusual property requirements, they will be stated in a special conditions attachment to the subaward.  These will include title restrictions and reporting requirements.

Any equipment purchased or constructed by a subrecipient with award funds must be approved in the budget.  If property is federally owned, the subrecipient  is required to comply with federal regulations (per A-110 or FAR 45.510, as appropriate) to adequately care for and maintain that property and assure that it is used only as authorized by the award.  The subrecipient’s approved property control system must include procedures necessary for accomplishing this responsibility.  Equipment reports must be submitted to OSU for referral to the sponsoring agency, as required by the prime award.

207:  Equipment

Property acquired from a research sponsor or purchased with sponsored research funds is accountable to the grant or contract for which it was obtained.  Contract authority must exist for the acquisition of facilities, special test equipment and other equipment on sponsored research funds.  Equipment budgeted in the grant or contract award is assumed to be approved by the award sponsor.  Additional acquisitions of capital equipment on award funds must be pre-approved in writing by the sponsor when required by the regulations of that sponsor.

There may be additional management procedures and restrictions required by an award sponsor.  In the case of federally sponsored research, procedures and restrictions are specified in OMB Circular A-110 (Property Standards section), OMB Circular A-21, the Federal Acquisition Regulations (FAR), and the NASA Grant Handbook, as well as terms of the individual contract or grant.  (Note: The NASA Grant Handbook has been updated as of October 19, 2000.  The revised rules are not retroactive, but affect awards begun after that date.)

Active information circulars are located in the NASA Grant & Cooperative Agreement Handbook.  Select circular number GIC 01-01, dated: March 29, 2001 Guidance on Property Administration Requirement for Special Purpose and General Purpose Equipment.)

Principal Investigators acquiring equipment for sponsored research are held accountable for following the sponsor’s requirements, as well, as OSU’s policies, regarding screening, acquisition, maintenance, physical inventories, reporting and disposition of property. 

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207-01:  Purchasing Equipment from OSU Surplus Property

Surplus property normally cannot be purchased on grants and contracts. The reason is that Property Administration is unable to verify what funding source originally purchased the property. OMB Circular A-110 and FAR state that property that was originally purchased with federal funds cannot be re-purchased with federal funds. Because of the CAS principal of consistency, this policy is applied to all sponsored projects.

The exception is when the surplus property did not come from OSU. Occasionally, OSU sells surplus property for other entities, like Benton County. 

Note: only scientific equipment can be purchased, not general-purpose desks and other items.

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207-02:  Trade-in of Capital Equipment

• Property Management should clear all assets prior to offering as a trade-in. Verbal approval will be given on the telephone.
• After approval, prepare a Property Disposition Request (PDR) to remove the traded asset from inventory. Be sure to note the amount of credit that is to be received from the vendor for the traded asset. If multiple assets are being traded there must be a specific amount for each asset – not a lump sum for all.
• The PDR should be attached to the Department Requisition that is sent to Purchasing.
• Purchasing will set up the Purchase Order in Banner to reflect the full value of the new asset (including the value of the trade-in credit, rather than less the value of the trade-in credit). There should be a text notation on the Purchase Order regarding the amount of credit to be received from the vendor.
• Purchasing will provide a copy of the PO as well as the original PDR to Inventory Control to keep on file until the asset is received and paid for.
• The invoice for the new asset must be processed for the full amount of the asset (including trade-in credit) even though the invoice from the vendor will probably be reduced by the value of the trade-in allowance. In order to pay the correct amount, a credit memo will be created in Banner for the amount of the trade-in allowance. Be sure to process the invoice and credit memo simultaneously (cross-referencing the document numbers in the text field of both). This allows the proper payment to the vendor.
• The credit memo will be set up for the amount of the trade-in, and posted to fund 095880 (Asset-Undistributed Income Clearing) and account code B5801 (Undistributed Income).
• Inventory Control will create the new asset record from the origination tag created by the invoice. Then the disposition of the traded asset will be processed in the Fixed Asset module under the ‘sale of asset’ function. This function will take the ‘proceeds’ of the sale (the credit amount in the undistributed clearing account from the credit memo) and return it to the appropriate departmental fund. This process allows the proper recording of the gain or loss on the disposal of the traded-in asset. Gain or loss will only be posted to 09XXXX Service Center and 1XXXXX Auxiliary funds.

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207-03:  Guidelines for Ownership Coding of Sponsor Funded Equipment

1. In determining ownership codes, the award or contract, subsequent official modifications and contract specific correspondence from the agency supersedes agency regulations.
2. Agency regulations are the specific guide to that agency’s implementation of OMB Circular A-110 (grants & cooperative agreements), and thus are the guidelines for equipment ownership coding in all areas not covered by the award document. Appropriate FAR clauses are used for contracts in conjunction with the award document.
3. Unless otherwise specified in the agency regulations or the agreement itself, contractor-acquired equipment valued at $5000 or more, purchased under agreements with agencies that require final equipment reports and provide disposition instructions, will be source coded “CI” (Conditionally Owned, Insured) or “FN” (Federally-owned, Not Insured) as appropriate.
4. Unless otherwise specified in the agency regulations or the agreement itself, all equipment purchased with grant funds from agencies that do not require final equipment reports or issue disposition instructions will be source coded “SI” (State-Owned, Insured).
5. Caution should be taken to avoid split purchase of a piece of equipment between agency funds which have “CI” or “FN” ownership codes unless it is the same agency, e.g., NASA.

   Any equipment being purchased on split funding that has state and restricted funds must have a title-to code of “SI” to be allowable.

6. “OI” Equipment does not belong to OSU and must be dispositioned at the end of the award. This equipment is usually left in a foreign country. The department is required to fill out a PDR form that will remove it from inventory. That form is to be approved by the Office of Post Award Administration. Also, the award must state that the piece of equipment is to be left with another party. All “OI” equipment must be ‘signed off’ by the receiving entity at the conclusion of the project.

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Additional Information

For additional information or clarification on equipment policies please refer to:

• Property Security Policy in the General University Policy Manual.
• Property Management Manual (PRO)

208:  Participant Support Costs

Post Award Administration processes:

1. Recurring long-term (more than 3 months) stipend payments,
2. OSU tuition payments, and
3. OSU health insurance reimbursements.
4. All stipends paid to non-resident aliens

Business Center’s are requested to process other participant costs:

• Short-term stipend payments (3 months or less)
• Fellowship/participant support payments can only be made with sponsored award  funds using a payment request form.
• Non-sponsored award fellowship and scholarship payments are made through the Financial Aid and Scholarship Office and are applied as credits to the student’s account.
• Payments processed in Banner must include the student’s name in the commodity line of an invoice or description line of a JV.  These documents must not include the student’s ID or social security number.  Also DO NOT include Student’s ID or social security number on original Banner FIS documents.

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208-01:  Participant Support Account Codes

55XXX for OUS students

2863X for Non-OUS students, Post Docs and workshop participants

Do not pay stipend payments to anyone on the State of Oregon’s payroll, unless concurrent employment is authorized.

551XX Account Codes

1. These account codes are not authorized for use with Education & General (E&G) funds.
2. These account codes are only allowed for use with sponsored awards.
3. These account codes are to be used when paying or reimbursing OUS students only.
4.   If paying stipend to a non-resident alien, account code 28632 should be used.

55102 Stipends – Expenditures in the form of subsistence allowances paid to students engaged in training or a sponsored program. This payment is not salary and is made primarily to defray general living expenses, although participation and adequate progress in research  project work is often required for continuous support.

55105 Travel Payment for Participant – Payments made on behalf of participants for travel in connection with the objective of the sponsored program. This code applies to transportation, meals, lodging and other travel expenses. Use this code even when travel is included as a part of the registration fee for a course or conference.

55106 Book Allowance for Participant – Payments made to a participant, either as a book allowance or reimbursement of expenditure.

55107 Room and Board for Participant – Expenditures for room and board for  participants under training or sponsored programs.

55108 Group Activities – Expenditures for cultural and recreational activities of participants in training or sponsored programs. This code covers group support, for which individual identification may not be practical. It also covers the cost of food, lodging, travel, admission fees, service fees, and equipment rental fees.

55109 Medical and Dental Payment for Participant – Expenditures for health care by licensed practitioners, whether or not the patient is confined to a hospital or infirmary. This code covers expenditures for medication, health insurance, laboratory fees and analyses.

55110 Miscellaneous Participant Support – Expenditures from participant support funds that cannot otherwise be classified.  This may include memberships, subscriptions, moving expenses, storage, photography, copying, computer supplies, research supplies, etc. when allowed by sponsor.

28630 NON-OUS Participant Support / Tuition and Registration Fees – Participant support for Non-OUS students and Non-OUS employees for tuition and registration fees paid to Non-OUS entities.

28631 NON-OUS Participant Support / Other – Participant support for Non-OUS students and Non-OUS employees for costs other than tuition and registration fees. This includes payments to workshop participants. This code covers housing, books, and stipends. It excludes travel costs. (Must have receipts)

28632 NON-OUS Participant Support-Non-Resident Alien – Non-resident  alien participant support costs that are not documented by receipts. Code covers tuition and registration fees, stipends, room and board, and book allowances. It excludes travel. Transactions are IRS form 1042S reportable.

28633 NON-OUS Participant Support – Book Allowance – Payments made to a non-OUS participant, either as a book allowance or reimbursement of expenditures.  The expenditures must be supported with receipts.

28634 NON-OUS Participant Support – Room and Board – Expenditures for room and board covering charges incurred by non-OUS participants under training or research programs. The expenditures must be documented with receipts.

28635 NON-OUS Participant Support – Travel Payment – Payments made on behalf of non-OUS participants for travel in connection with the objective of the sponsored award . This code applies to transportation, meals, lodging, and miscellaneous travel expenses. Expenses must be documented with receipts.

28636 NON-OUS Participant Support – No Receipts – Non-OUS participant support costs that are not documented by receipts. Code includes tuition and registration fees, stipend, room and board, and book allowances. Transactions are IRS form 1099 reportable.

See FIS 410-32 Participant Support Costs or the OUS Fiscal Policy Manual, formerly the FASOM Manual, for additional information or clarification.

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208-02:  Reimbursement for Participants

Reimburse participants for books, travel and research expenses when allowed on sponsored project.

• A reimbursement form signed by the participant is required.
• Attach corresponding backup information and original receipts . This may include credit card receipts, OSU bookstore receipts, conference registration forms, hotel bills, etc.
• Travel costs may be allowed as per diem payments, as permitted by OSU policy.

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208-03:  Making Payment Directly to a Vendor for Participant Support

The procedure is used when paying a vendor directly on behalf of the participant . This payment must be tied to the participant for audit/tracking purposes.

See FIS 1106-04: Payment when Check Disbursed to other than Vendor for guidance in entering a different check payee from the vendor.

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208-04:  New Fellow/Participant

When a new sponsored award  is received that supports a new fellow/participant, instruct the participant to contact the Office of Post Award Administration at 7-4711 or come to B306 Kerr Administration Building.  Additional information is required to start the process.  See the Office of Post Award Administration website for additional information.

1. Name of participant
2. Student ID number
3. Campus phone/email address
4. Student status: Graduate, Undergraduate, Post Doc
5. Residency status  
6. Complete vendor activation form   
7.  Other concurrent support  

Stipends  are normally processed  so that the fellow/participant receives the funds  on the first of the month for that current month.   Direct deposit of funds is encouraged.

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208-05:  Reporting

At the end of each month the Office of Post Award Administration provides the Financial Aid Office with a list of those students receiving participant support, amount and type.

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208-06:  Correcting JV’s

When processing a correction to participant support, put student’s name on description line.  DO NOT put student ID or social security number in description line or text.

210-01:  Gift Types

Gift Funds:

1. Are established upon request for affiliated foundation donations to OSU. 
2. Are established for direct gifts to the university.
3. Generally, are not defined at a level lower than the department.
4. Use activity codes to further define donations and expenditures.
5. Should not be deposited into or expended from OSU education and general funds, statewide funds or designated operations funds.
6. Can be expended when cash is available.
7. Are not budgeted.
8. Can have all allowable expenditures for OSU placed on them.
9. Fundraising or donor-related activities should be paid directly from the affiliated foundation.

Gift Fund Account Codes

FSXXXX – Any OSU foundation source

438XXX – Endowment earnings from OSU Foundation with State match (008XX)

FEXXXX – Endowment earnings from OSU Foundation with no State match

FAXXXX – Gifts from Agricultural Research Foundation
Note: If fund title contains an end date, this fund is a contract, not a gift.

M2XXXX – Gifts to OSU from any outside source for restricted expenditures.

M3XXXX – Gifts to OSU for Library Book purchases

M4XXXX – Gifts to OSU for scholarships.  Also OSU endowment earnings for scholarships.

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210-02:  Revenue

Donations or gifts received for OSU restricted gifts should be forwarded to the Office of Post Award Administration for reporting and deposit.  Include with the check any letter or other documentation received from the donor.  OSU cannot accept donations from current employees or emeritus faculty.  These donations must go through OSU Foundation. The Office of Post Award Administration (OPAA) will send each donor an acknowledgement as required by IRS statutes.

All gifts to OSU are charged a gift fee. See GCG 210-07: Gift Fees.

See GCG 202: Revenue for further information on revenue.

Information on gifts to the OSU foundation is located on the OSU Foundation website.

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210-03:  Deposits into Agricultural Research Foundation (ARF) and OSU Foundation (OSUF)

Deposits into OSUF and ARF are restricted to true gifts or proceeds from fund raising activities in which the donor intends that the gift go to the foundation(s). The following procedures apply:

1. Gifts deposited into foundations must be payable to the foundations. If checks or other negotiable paper are made payable to Oregon State University, they must be deposited directly with OSU. If the department can document that the donor intended the gift to go to the foundation, Business Affairs will issue an OSU check to the foundation.
2. Copies of all documents supporting the fact that it was the donor’s intent that funds be deposited to the foundation instead of OSU must be attached to the check request.

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210-04:  Transferring Funds from OSU Foundation or Agricultural Research Foundation to OSU

Funds transferred from the OSU Foundation (OSUF) or Ag Research Foundation (ARF) must be placed in an OSU restricted fund that properly reflects their intended use.

To transfer amounts from OSUF and ARF to restricted OSU funds, send a departmental request to OSUF or ARF that complies with the donor’s restrictions. This allows the foundations(s) to make a deposit to the OSU restricted fund. OSUF requires data warehouse query be attached as evidence that OSU has approved expenditure payments which OSUF is reimbursing.

Restricted OSUF and ARF funds should not be over drafted.  Departments should request that funds from the foundation(s) be transferred before or as soon as possible after the expenditures are made.

These funds are interest bearing.  The Oregon University System (OUS) Controller’s Division will charge interest to any fund in overdraft status at month-end, as is the policy for all gift funds.  Payroll and other payroll expenses (OPE) can be requested one month in advance.

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210-05:  Gift Funds

Gifts cannot be deposited into general funds.  Checks received as gifts should be routed to the Office of Post Award Administration for deposit along with donor letter and/or restrictions.  Special indexes have been established for each department for the deposit of gifts.  These indexes all begin with “M”.  Gifts cannot be deposited into an FS index.  These indexes are only for deposits from OSUF.  See GCG 210-07: Gift Fees.

When a gift is received that is for the specific purpose of cost sharing, the Office of Post Award Administration will set up a restricted fund to hold the cash donations for the cost share.  A gift fee is not applied to these funds.

Information on gifts to the OSU foundation is located on the OSU Foundation website.

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210-06 Interest

Gift funds earn, or are charged, interest based on the cash balance at the end of each month.  This interest is recorded each quarter.

Purpose

To explain the Personnel Activity Reporting (PAR) system. 

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Background Information

The Personnel Activity Reporting (PAR) system is the method used by Oregon State University to reasonably substantiate the activities (effort) of employees who are compensated in any part by restricted funds or cost share funds as required by OMB Circular A-21.  The PAR system is only an effort tracking system that recognizes where an employee’s effort is applied.

This system DOES NOT alter the indexes from which salaries and wages are paid.  The information accumulated on the PAR system is subject to audit verification and, if found to be inaccurate by federal auditors, disallowance of both direct and indirect costs can be assessed.

Requirements of OMB Circular A-21, Section J.8:

1. Payroll system will reasonably reflect the activity for the employee.
2. Method must recognize the principle of after-the-fact confirmation.
3. Practices vary as to activity constituting a full workload.  Therefore, the payroll system may reflect categories expressed as percent of total distribution.
4. Payroll charges may be made initially to sponsored agreements on basis of estimates made before services are performed. When such estimates are used, significant changes in the work activity must be identified and entered into the payroll distribution system. Short-term fluctuations need not be considered as long as the distribution is reasonable over the longer term, such as an academic period (school term).
5. Confirmation of effort (activity reports) will be reported on a percentage basis and reasonably reflect the activities for which employees are compensated by the institution.
6. Effort confirmation will be signed by the employee, principal investigator, or responsible official using means of verification that the work was performed; i.e., person with first-hand knowledge.
7. Reports will be prepared each academic term for all academic, professional faculty, or classified employees who are paid either totally or in any part by restricted funds or by cost sharing funds. For other employees (students and temporary), no effort reports are generated.
8. Time cards or other forms of after-the-fact payroll documents should be signed by the principal investigator as original documentation for payroll charges.  Copies of these forms should be kept at the department and will then serve as documentation for effort reporting purposes.

System Approval:

1. The PAR system is approved by our cognizant audit agency DHHS.
2. Method of meeting effort reporting requirement is in our CASB Disclosure Statement DS-2.

Uses for Effort Reports (current PAR Forms):

1. The OMB A-21 requirements are fulfilled.
2. State, federal compliance auditors, and other agency auditors review these documents.  There could be possible dollar disallowance's if the PAR forms are not completed and signed.
3. The forms should be used by departments to properly classify the use of individual offices (research or instruction) in the university’s space inventory. The space inventory is used for many purposes, including the F&A Rate Proposal.
4. When effort is expended on a sponsored agreement and not charged to the sponsor, PAR forms can be used to document the effort as university cost share.

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Policy

At the end of each quarter, PAR forms are produced from the HRIS payroll system.  Parameters are selected to identify the calendar year and quarter to be reported.  Selection is limited to only those individuals who have been paid either in full or in part during the quarter from restricted grant funds or cost sharing funds.  The PAR form has been designed to list all the indexes from which the individual is paid, the amount paid from each index, and the percentage of total pay for the quarter that amount represents.

PAR forms will be sorted by home organization.  The Office of Post Award Administration will send the forms to the designated PAR coordinator for each department.

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Procedure

Purpose

To ensure that cost sharing requirements of sponsored agreements are proposed, accounted for, and reported in a manner consistent with the requirements set forth in federal regulations, primarily the Office of Management and Budget (OMB) Circulars A-110 and A-21, as well as Cost Accounting Standards. 

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Background Information

Once an award is made, ALL cost sharing commitments are considered to be mandatory and represent binding obligations by the university regardless of whether cost sharing is mandated by the sponsor or it is voluntarily offered by the university or principal investigator.  Therefore, the use of cost sharing should be kept to a reasonable level because of the burden that cost sharing places on university and departmental resources.

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Definition

Cost Sharing

That portion of a project or program cost that is not reimbursed by the sponsor, but is nonetheless part of the costs of that project or program.  Cost sharing represents a commitment by the university or third party and may be in the form of dollars, commitment of effort or in-kind contribution.  The sponsor, as a condition of the award, may require cost share or the university may voluntarily offer it. 

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Policy

The amount of cost sharing should be balanced between what is mandated by the sponsor, what is necessary for the proposal to be competitive, and what can be committed and accounted for after an award is made.  If cost sharing is not required by the sponsor, necessary for completion of the project, or to ensure the competitiveness of a proposal, principal investigators should refrain from making such commitments voluntarily.

Where cost sharing is not required as a condition of the award, mandated for the competitiveness of the proposal, and if the effort expected to be contributed to the project is less than 5 percent of an individual’s total effort, the following statement should be inserted in the text of the proposal or on the budget justification:

"Oregon State University assures that the faculty member will make a contribution to this project, but the expected level of effort is not a significant portion of the individual’s overall effort."

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Procedure

Typical Categories of Cost Sharing

Expenditures recorded as cost share must be:

• necessary and reasonable for the project’s objectives,
• incurred during the effective dates of the award,
• verifiable, either within the university’s accounting system or properly documented, if provided by sources outside the university, and
• (for federal awards) allowable under OMB Circular A-21 and guidelines of the funding agency .

Expenditure categories that CANNOT be used for cost share include:

• use charges for equipment, computers, or networks that already exist,
• use charges for land or buildings owned by OSU,
• salaries and fringe benefits of administrative/clerical personnel (unless these costs have been approved in the proposal process as cost share and would be allowed as a direct project expense),
• funds received from a federal source (unless the federal agency agrees to cost share with another federal sponsor), and
• expenditures that have previously been reported as cost share.

Mandatory Cost Share
When an agreement is received that has cost sharing indicated (either in the agreement itself, or in the proposal, which becomes a part of the agreement), The Office of Post Award Administration will set up the appropriate cost sharing fund(s), and notify the PI and college/department accountant.

All cost sharing expenses for the project will be recorded in the unrestricted cost share fund.  The college/department accountant will complete Labor Distribution forms as needed to reflect appropriate salary. Equipment purchases, travel or other cost share expenses will be charged directly to the cost share fund. As each expenditure is posted to the cost share fund, a corresponding transaction will be automatically posted moving funds required to cover this expenditure from the unrestricted fund budget that has been designated for cost share recovery.

If mandatory cost share is not met, the award will be reduced in proportion to the amount of cost share not met. The proportional amount of cost share not met will be charged to the department as a cost overrun. The same amount will be returned to the sponsor.

Non-Mandatory Cost Share
The department will notify The Office of Post Award Administration to set up a cost share fund/index when needed for non-mandatory cost share.

Grant Specific Cost Share Documentation
When an award requires cost sharing, documentation will be posted in Banner FIS through use of an unrestricted fund, which will be set up for each agreement which requires cost sharing. The grant roll-up and index will identify the cost sharing with the sponsored grant and fund in the following manner.

A matrix has been established which identifies a single “general fund” index for each department or organization as the most likely to cover the costs for cost sharing. Cost share methods have been established through a Banner FIS table which links the cost share fund to that organizational general fund index. As each charge is posted to the cost share index, Banner FIS automatically makes a corresponding transfer to credit the cost share index and debit the general fund index for the expenditure. These transfers appear as account 9xxxx entries. The result is that the cost share index always maintains a “zero” bottom line, and year-end adjustments are unnecessary.

No budgets are applied to the cost share indexes.  Instead, the information is entered into an Access database that is linked to OSU’s data warehouse. The resulting cost share report displays the beginning budget that has been committed, as well as picking up any costs which have been posted through the Banner FIS System and calculating a remaining balance spread out over the life of the award. Copies of the updated cost share reports are distributed to all departments twice per year.

NSF—Minimum 1% Cost Share Documentation

The National Science Foundation has a statutory requirement of cost sharing a minimum of 1% of the aggregate total costs of all projects funded. Each department that has active NSF awards has been assigned a cost share index to record expenditures toward meeting this requirement.

Any NSF project that has specifically required cost sharing will have a separate cost sharing grant, fund, and index established for documentation of those costs. These projects are exempt from the 1% requirement.

Also exempt are:

1. Awards for international travel only (usually related to sabbatical leave).
2. Awards for construction, improvement or operations of facilities.
3. Awards for purchase of equipment only.
4. Awards for Ship Operations (COAS).
5. Awards for education and training; this includes individual fellowships.
6. Awards for purpose of publication and translation of scientific data.
7. Awards for workshops.

USDA/PNW GRA Fee Remission Documentation

USDA/Pacific Northwest Area (PNW) has determined that GRA Fee Remissions are an allowable cost share item. Each department has been assigned a cost share index designated to receive these charges. When GRA salaries are budgeted to the sponsored index, account code 10632 is used to pay these costs which alerts the Payroll Office to record the corresponding fee remission to the cost share fee remissions index.

General GRA Fee Remissions

When graduate research assistants’ salaries cannot be charged directly to the project (per sponsoring agency’s written policy), they should be charged to the cost share index.  The corresponding fee remissions will be posted by Payroll to special cost share indexes that have been set up for each department. The process is triggered by the use of account code 10632 used when paying the GRA salaries on the cost share index.

To document cost share from outside sources, please use the "Cost Share from Outside Sources" form available on the forms online web page maintained by the Office of Post Award Administration.

Purpose

To ensure that income generated by grant-funded programs is recorded appropriately and is easily identifiable for monitoring and reporting.  This policy allows program income, as well as costs to be charged against that income, to be recorded in a companion index and easily reported in conjunction with the grant revenue and expenditures.   Identify and recording program income and costs in this manner will ensure compliance with the requirements set forth in federal regulations, primarily the Office of Management and Budget (OMB) Circulars A-110 and A-21, as well as Cost Accounting Standards. 

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Background Information

Prior to the implementation of the Grants Billing module in Banner, all program income and associated costs could be recorded in the grant fund and index and reported appropriately.  Limitations with the Grants Billing module, however, require implementation of a different mechanism for properly recording these transactions.  The process described herein allows these costs to be reported with the grant, while also allowing for full functionality of Grants Billing.

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Definition

See GCG 202-01: Program Income. 

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Policy

All program revenue and associated expenses will post to the main grant.  At least annually, before fiscal year-end close, a transfer will be completed by OPAA to record expenses in the program income index.  Program revenue will be posted directly to the program income index.

As with all costs, departments should have all program income costs posted to the main award in time to allow OPAA to meet the deadline in submitting the final invoice and financial report to the sponsoring agency (see closeout policy GCG 302 for further detail).

Procedure

OPAA will set up a companion index to record program income (similar to the mechanism used to record cost share).  To do so, a grant consistent with the number of the corresponding grant but ending in “P” will be established, as will a companion fund and index.   This grant will not be set up under Grants Billing.  The same org and program codes as the main award will be used in setting up the program income index.  Program income expenses will be charged an indirect cost rate of 8% on total direct costs unless the specific award is restricted to a rate lower than 8% TDC

For example:
Parallel grant not set up on Grants Billing (like cost share)

If “P” index is not available, another index will be assigned.

Typically, program income expenses on the main award will be transferred to the “P” index via journal voucher.  It will use account codes consistent with the cost overrun JVs, as in the following example:

A final journal voucher transferring program income-related costs will be done prior to the final invoice, thereby allowing the project-related costs to be located on the project to which they are related.  This will prevent the sponsoring agency from being billed for these costs.  As the program income grant will not be set up on Grants Billing, all revenue will be deposited directly to the proper 0xxxx revenue code on the program income index.  Below are the T accounts showing anticipated expenses and transactions.

*8% F&A on total costs will be charged consistent with the Designated Operations rate (unless grant is limited to less than 8%).

Purpose

To facilitate the closing of awards.

Applicability

All employees.

Policy

Awards will be closed in a financially responsible manner and within the appropriate time period for closeout. All reports and documents necessary for closeout will be completed and submitted by the appropriate deadline.

Procedure

Purpose

To identify the procedures for closing awards.

Applicability

All employees.

Background

The Office of Post Award Administration has designed a suggested Grants & Contract Closeout Check-off Sheet to help facilitate the closeout process. A sample of the Grant & Contract Closeout Checkoff Sheet is located on the Business Affairs website.

Definition

Closeout Date

The date that all final documents must be received by the sponsor.

Closeout Date

The period that all final documents must be processed and sent to the sponsor. For example, if it says 90 days, you will have until closing of the period following 60 days after the end date to make corrections. To allow for processing time the department should process all corrections 30 days prior to the contractual due date of reports. Remember that this information will be noted on the Award Information Sheet of the original award only. It will not be noted on the Award Information Sheet of future amendments.

Policy

The Office of Post Award Administration will identify the closeout period on the original Award Information Sheet. Departments will facilitate the closeout process in a timely manner including the processing of necessary corrections and adjustments.

Procedure

The request for Technical Report/Patent Information is uniformly carried out for all agencies except National Science Foundation (NSF). Notice is electronically received in the Office of Post Award Administration from NSF when the technical reports are submitted. Patent reports are not required for NSF although the OSU Technology Transfer office should still be contacted for any possible patents.

Awards from DOD (Army, Air Force, ONR), Dept of Energy, or NASA requires Standard Form 298 "Report Documentation Page" when ONR has administrative authority. Even though a complete Technical Report may have been submitted to the program officer, the tech report will not be checked off as completed until the SF 298 is submitted.

• The Office of Post Award Administration sends out the first Tech Email within 30 days after the end date of the award with a respond by date. This request for information will be sent to the:
  > Department Accountant and the PI.
• If the first request is not received back, a second request is sent out after the original respond- date.
• If the second request is not answered, a third request is sent out stating that the Department Head and the Dean will be notified.
• If no response has been received, the Director of Sponsored Programs is notified.

To view a sample of the Tech Email, click on "Forms" from the Office of Post Award Administration web site and choose "Tech Email",

Closing the Grant Fund

1. There is a button on data warehouse to help monitor awards that are ending. It is under multi-year operating ledger. The button is titled "Ending Award by Org". The query will prompt for the org number and date. It is recommended that this report be run at the beginning of each month entering the current date at the prompt, paying close attention to projects ending within the next 60 days that have a balance. Any necessary corrections and adjustments should be started at this time to facilitate the closeout process. The department should continue to monitor these awards until they show up on the terminated funds report, which is located under current operating ledger in data warehouse. Charges have been known to show up after the end date unexpectedly. Note that the report may duplicate fund numbers when there has been a change in F&A cost basis, cost share basis or Fund Financial Manager attributes, there will be lines for the activity showing the old and new data. The report will also list funds with zero balances until the grant is closed. Once the grant is closed, the fund will drop off this list. Funds with zero balances can be ignored.
2. The report FGROPNE in Banner FIS can be run to check for open encumbrances. All encumbrances must be liquidated before indexes and funds can be terminated. (Subcontract encumbrances will be liquidated by the Office of Post Award Administration).
3. There is a canned query in the HR Data Warehouse that can be run to check for default pay. The buttons are titled "active jobs for an index" and "active jobs for a fund". If there is still default pay set up at the time of closure, and it is a student or temporary job, the Office of Post Award Administration will fill out a labor distribution change request form moving the default pay to "ZNOPAY". If not a student or temporary job, the Office of Post Award Administration will request the department to move the default pay or terminate the employee job in HRIS, if appropriate.
4. Departments are responsible for informing the Office of Post Award Administration of adjustments or corrections that have not posted to Banner FIS before the department's closeout deadline. This includes invoices, journal vouchers and payroll documents.
5. If the fund has been expended in excess of the approved budget at end of closeout period, the Cost Overrun Policy will be initiated. See GCG 209-03: Grant and Contract Overrun Policy.

The A-133 single audit is intended to provide a cost-effective audit.  Efficiencies can be considerable when an organization-wide audit, or single audit, is conducted in lieu of multiple audits of individual Federal programs.

Any Non-Federal Entity that expends $500,000 or more in Federal awards in its fiscal year is required to have a single audit.  OSU meets this criteria.

Non-Federal Entities subject to audit must:

1. arrange for a timely audit,
2. prepare appropriate financial statements and a schedule of expenditures of Federal awards,
3. ensure the audit is properly completed,
4. submit the single audit report when due, and
5. take corrective action on audit findings.

The single audit report includes:

• the financial statements (auditee’s responsibility to provide),
• a schedule of expenditures of Federal awards (auditee’s responsibility to provide),
• auditor’s opinions on the fair presentation of the financial statements and schedule of expenditures of Federal awards,
• auditor’s report on internal control and compliance pertaining to financial reporting,
• auditor’s report on internal control and opinion on compliance pertaining to major programs,
• auditor’s schedule of findings and questioned costs,
• auditee’s corrective action plans, and
• a summary schedule of prior audit findings which includes planned and completed corrective actions (auditee’s responsibility to provide).

The auditee is responsible for submitting a report that meets the requirements of the Circular.

If the auditee is a subrecipient, it must also forward a copy of a report containing audit findings to affected pass-through entities.  If the report contains no findings, the subrecipient is only required to provide the affected pass-through entities with a notification that the audit was completed.

The auditee is responsible for preparing a corrective action plan, taking corrective actions on audit findings, and reporting the status of corrective actions in subsequent reports.

An audit finding may include questioned program costs.  If any of the questioned costs are disallowed by the management decision, the auditee may have to refund the disallowed amount.

Most audit reports are a matter of public record.  Information is provided on the results of the audit that is entered into a database maintained by the Federal Audit Clearinghouse.  The Federal Audit Clearinghouse serves as the central collection point, repository, and distribution center for single audit reports.

Cognizant Agency – Recipients who annually expend awards in excess of  $25 million have a Federal cognizant agency for audit.  Oregon State University’s cognizant agency is the Department of Health and Human Services (DHHS).

Pass-Through Entities – Recipient entities are responsible for ensuring their subrecipient(s) meet the requirements of the Circular and specific requirements of the award.

Areas that auditors review: (but are not limited to)

• Cost Sharing - Is cost share required? If so, has cost share been met and documented?
• Equipment - Was approval obtained to purchase equipment? Was any equipment purchased within the last 6 months of the project? Are title-to codes correct?
• Rebudgets – Are rebudgets properly justified? Was prior approval obtained, if required?
• Dates - Are all transactions within start and end dates of the award?
• F&A Cost Rate - Is the correct basis being used?
• Student Pay – Are time certificates properly signed?
• Reports – What reports are required? Due dates? Dates that reports were submitted?
• Subcontracts – Are subawards reviewed, approved, spent correctly in the proper time period?
• Outside Program Income – What was it for? What method was used to account for it?
• Fee remissions – Approved by sponsor? Was there associated salary? Recruitment and Retention Differential?
• Effort Reporting documentation – Do we have signed PAR forms for everyone (except students) paid on award? Do we have time sheets for students?

Occasionally, the Office of Post Award Administration may contact departments to submit documentation to help assist in the audit process. Some of those areas might be student timecards, technical reports, etc.

If the Department or PI receives notification that a sponsor is coming for a site visit or audit, the Office of Post Award Administration should be contacted so the appropriate personnel can be included in these activities.

To view additional information on Federal audits see the Office of Management and Budget's webpage on the White House website.

In 1998, Congress passed a, now controversial, two sentence amendment to the budget bill ordering the Office of Management & Budgets (OMB) to revise regulations governing federal research grants to ensure that all research results and data would be publicly available through Freedom of Information Act (FOIA) requests.  The public comment period generated over 12,000 reactions.  Many in the scientific community feared that such early and unrestrained access would chill the willingness of individuals and businesses to participate in research.  Opponents of this proprietary information could not be assured confidentiality.

The OMB issued revised regulations, effective November 8, 1999, which limit public access to sensitive data that is part of federally financed scientific research projects.  The regulations redefine research data thereby providing more concise guidance on what data can be accessed under federal FOIA requests.

OMB modified the regulations in response to public comment.  Public Law 105-277 now specifically excludes from the definition of research data the following:

• preliminary analyses,
• drafts of scientific papers,
• plans for future research,
• peer reviews, or communications with colleagues,
• trade secrets,
• commercial information,
• materials necessary to be held confidential by a researcher until they are published, and
• personnel and medical information and similar information, the disclosure of which would constitute a clearly unwarranted invasion of personal privacy, such as information that could be used to identify a particular person in a research study. 

The changes set forth in Public Law 105-277  further define "published" and the term used by the federal government. 

Procurement contracts are also excluded from the scope of the revised regulations.

Questions may be directed to OSU’s legal advisor at (541) 737-2474.

Additional Information

Federal Register Online

Federal Register, October 8, 1999, Volume 64, Number 195, pages 54926 – 54930

The Office of Management and Budgets (see Grants Management)

OSU Websites

Granting Agency Websites

Other Reference Websites

2009

2008