Grant Procedures

Principal Investigator is a university employee who has a Full-Time position that includes:

1. tenure-track faculty 
2. non-tenure-track faculty/non-tenure-track clinical faculty
3. instructors/lecturers/emeritus faculty(special status)
4. senior research investigators/graduate students
5. librarians/curators/administrators/staff 

The Process begins three weeks before the grant submission deadline, with the Principal Investigator (PI) informing OGRA of the Proposal Opportunity or Notice of Funding Availability (NOFA).

1. The Grants and Contracts Administrator (GCA), Ms. Angela Hopgood Miller (ahopgood@csu.edu), provides the Intent to Submit a Proposal (ISP).  The applicant must read and completes the ISP carefully. The form is routed for approval once the Faculty/PI submits the ISP.  OGRA sets up the Faculty/PI as a project manager in the project workspace in Grants.Gov.
2. Eight business days before grant submission, the PI sends a project summary (or scope of work) and the proposal’s budget for approval. At this time, the PI informs if letters of support from the University, Certifications, or Memorandums of Understanding (MOUs) are needed to submit the proposal.
3. As soon as the ISP is approved, if a subrecipient is identified, the Grants and Compliance Specialist (GCS), Dr. Julia Siwierka (jsiwierk@csu.edu) sends the Subrecipient Commitment Form (SCF) to the subrecipient for completion. SCF returns to GCS for review for risk assessment. If GCS determines that the subrecipient is not eligible, the Faculty/PI is notified, and another subrecipient is identified.
4. Four business days before the submission deadline, the PI sends the full proposal to OGRA for final review and submission.

• Grants.gov: the official website for government grants in the United States where most public funding opportunities can be found. The federal government's free website is where federal agencies post discretionary funding opportunities, and grantees find and apply for them.  It also allows the Office of Grants and Research Administration to quickly set up workspaces for project development with the project manager and team. 

• Invoicing Template: An invoice is a document that lists goods that have been supplied or services that have been done and says how much money you owe for them. This is an example of what OGRA receives from vendors.

• Subrecipient Invoicing Procedure: All subrecipient invoices (certified by an authorized signatory) should be sent to the appropriate Principal Investigator and OGRA's Grants Compliance Specialist (GCS) for subrecipient compliance/monitoring purposes. These invoices should include supporting documentation.  GCS will request additional supporting documentation on all invoices if necessary.  All invoices must follow a required form (please see sample invoice template) and should reflect the current approved budget, expenses, and remaining available balance.  If necessary, invoices are sent back for any corrections and inconsistencies.  Otherwise, upon review, the GCS will send these invoices back (via email) to the appropriate PI for their review and approval. Once the invoice is approved by the PI, the same email is sent to the appropriate PI's Program Specialist or Grant Coordinator to be uploaded to CSU Buy for payment processing.  

Circulars

For more information, visit White House website

As of 08.13.2020, final updates and addition on Grants and Agreements Guidance 

2 CFR PART 25 Universal Identifier and Systems for Award Management

UEI replaces DUNS

What is the Unique Entity Identifier (UEI)? The Unique Entity Identifier, or the UEI, is the official name of the “new, non-proprietary identifier” that will replace the D-U-N-S® number. The UEI will be requested, and assigned by, the System for Award Management (SAM.gov).

2 CFR Part 170 Reporting Subaward and Executive Compensation Information -  Required reporting of first-tier subawards, including each action that equals or exceeds $30,000.  Such reporting will continue to be conducted through www.fsrs.gov.

2 CFR Part 183 Never Contract with the Enemy NEW - 2 CFR Part 183 Never Contract with the Enemy applies ONLY to awards exceeding $50,000.00 and performed outside the U.S., including U.S. territories.  It also applies to a person or entity actively opposing U.S. or coalition forces involved in a contingency operation (where members of the Armed Forces are actively engaged in hostilities).

2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

2 CFR 200.216 STRICT Prohibition on certain telecommunication and video surveillance services or equipment -  prohibits federal award recipients from using government funds to enter into contracts (or extend or renew contracts) with entities that use “covered telecommunications equipment or services,” even if the contract is not for the purchase of such equipment or services. Covered telecommunications equipment or services is defined as telecommunications equipment produced by:

• Huawei Technologies Company
• ZTE Corporation
• Hytera Communications Corporation
• Hangzhou Hikvision Digital Technology Company
• Dahua Technology Company
• any subsidiary or affiliate of such entities

Federal awarding agencies must work with OMB to assist entities affected by this provision. If you are concerned that your organization may have entered into contracts that this provision would prohibit, reach out to your contacts at the federal awarding agency or pass-through entity for further information. Contracts need to include language addressing this prohibition as well, even if the contract is not intended for this purpose.  This also applies to the allowability criteria on procurements made in indirect cost.

2 CFR 200.344 Close-out timeframe to submit reports and liquidate obligations

• From 90 days to 120 days
• Deadline extensions are ONLY for the PRIME recipient, NOT the subrecipient

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

On December 2014, the Office of Management and Budget (OMB) officially implemented the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. There were eight circulars combined into the Uniform Guidance (UG) and also referred to as A-81 (due to eight circulars combined into one). The consolidation was made to streamline the federal grant-making and monitoring process, ease the administrative burden for grant applicants and recipients, and reduce the risk of waste, fraud, and abuse. 

These Office of Management and Budget (OMB) circulars fall into three main categories: Administrative requirements to Sub Part A through D (A-102, A-89 & A-110), Cost Principles to Sub Part E (A-122, A-87, & A-21), and Audit Requirements to Sub Part F. Below is a summary chart for easy reference.

OMB CIRCULAR	PARTICULARS Administrative requirements to Sub Part A through D
A-102	Grants and Cooperative agreements with state and local governments
A-89	Catalog of Federal Domestic Assistance
A-110	Uniform Administrative Requirements for Grants and other agreements with institutions of Higher Education, hospitals and other Non-Profit Organizations
Cost Principles to Sub Part E
A-122	Cost Principles for Non-Profit Organizations
A-87	Cost Principles for State, Local, and Indian Tribal Government
A-21	Cost Principles Applicable to Grants and Contracts at Educational Institutions
Audit Requirements to Sub Part F
A-133	Requirements of an audit and explains the responsibilities of the institutions, the agency, and the auditor.
A-50	Audit Follow-up

OMB Circular A-21 - Cost Principles for Educational Institutions (05/10/2004) PDF (109 pages,b263kb)

• A-21: 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 do not attempt to identify the circumstances or dictate the extent of agency and institutional participation in financing a particular project. The principles are designed to provide that the Federal Government bears 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. Provision for profit or other increment above cost is outside the scope of this Circular.

OMB Circular A-110 - Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations PDF (33 pages, 243kb)

• A-110: This Circular sets forth standards for obtaining consistency and uniformity among Federal agencies in administering grants to and agreements with institutions of higher education, hospitals, and other non-profit organizations.

OMB Circular A-122 - Cost Principles for Non-Profit Organizations (05/10/2004) (55 pages, 220kb)

• A-122: This Circular establishes principles for determining the costs of grants, contracts, and other agreements with non-profit organizations. It does not apply to colleges and universities which are covered by Office of Management and Budget (OMB) Circular A-21, "Cost Principles for Educational Institutions"; State, local, and federally recognized Indian tribal governments which OMB Circular A-87 covers, "Cost Principles for State, Local, and Indian Tribal Governments"; or hospitals. The principles are designed to provide that the Federal Government bears its fair share of costs except where restricted or prohibited by law. The principles do not attempt to prescribe the extent of cost sharing or matching on grants, contracts, or other agreements. However, such cost sharing or matching shall not be accomplished through arbitrary limitations on individual cost elements by Federal agencies. Provision for profit or other increment above cost is outside the scope of this Circular.

OMB Circular A-133 - Audits of States, Local Governments, and Non-Profit Organizations (06/24/1997, includes revisions published in Federal Register 06/27/03) PDF (33 pages,127kb)

• A-133: 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.

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As an integral part of its institutional mission, Chicago State University (the "University") upholds the principles of free and unbiased inquiry, transfer of ideas and technologies for public benefit, and stewardship of the resources entrusted to it. As Faculty and Staff increasingly build complex relationships with private companies, financial and other internal and external relationships must not conflict nor appear to conflict with these principles.

Faculty and Staff of the University have a professional obligation to act in the best interests of the University. The Financial Conflicts of Interest Policy ("Policy") for Research delineates the requirements for disclosing significant financial interests that may constitute financial conflicts of interest, regardless of whether the Faculty or Staff is performing research under U.S. Public Health Service ("P.H.S.") grants and cooperative agreements.

Faculty and Staff must report to the Research Integrity Officer if they are aware of any not-disclosed Financial Conflicts of Interest of other personnel of the University.

Policy

Training

Disclosure Form

Allowable, Allocable, and Reasonable Costs

The legitimacy of a cost charged to a specific sponsored research award will depend on the cost concept on allowability, allocability, and reasonableness of a given cost.  The Office of Management and Budget (OMB), the sponsor's specific requirements, the University policy, and federal cost principles defined and determined an expense's allowability, allocability, and reasonableness.  Payment Requests must be supported by appropriate documentation for the cost incurred and paid on a grant to be considered allowable, allocable, and reasonable otherwise. It will be treated as unallowable. If you are unsure whether a particular expenditure is allowable, consult your approved project budget and/or contact the Office of Grants & Research Administration if additional assistance is needed.  PART 200 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards - Subpart E - Cost Principles provided the following:

Allowability

§200.403 Factors affecting allowability of costs.

Except where otherwise authorized by statute, costs must meet the following general criteria to be allowable under Federal awards:

1. Be necessary and reasonable for the Federal award's performance and be allocable under these principles.
2. Conform to any limitations or exclusions set forth in these principles or the Federal award regarding types or amount of cost items.
3. Be consistent with policies and procedures that apply uniformly to the non-Federal entity's federally financed and other activities.
4. Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
5. Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes only, as otherwise provided for in this part.
6. Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in the current or a prior period. See also §200.306 Cost sharing or matching paragraph (2).
7. Be adequately documented. See also §§200.300 Statutory and national policy requirements through 200.309 Period of performance of this part.

§200.404   Reasonable costs.

A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Reasonableness is particularly important when the non-Federal entity is predominantly federally funded. In determining the reasonableness of a given cost, consideration must be given to the following:

1. Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award.
2.  The restraints or requirements imposed by such factors as sound business practices; arm's-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award.
3. Market prices for comparable goods or services for the geographic area.
4. Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable, its students or membership, the public at large, and the Federal Government.
5. Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award's cost. [78 FR 78608, Dec. 26, 2013, as amended at 79 FR 75885, Dec. 19, 2014] 

§200.405 Allocable costs

1. A cost is allocable to a particular Federal award or another cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. This standard is met if the cost:
   1. Is incurred specifically for the Federal award;
   2. Benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods; and
   3. It is necessary to the overall operation of the non-Federal entity and is assignable in part to the Federal award in accordance with the principles in this subpart.
2. All activities which benefit from the non-Federal entity's indirect (F&A) cost, including unallowable activities and donated services by the non-Federal entity or third parties, will receive an appropriate allocation of indirect costs.
3. Any cost allocable to a particular Federal award under the principles provided for in this part may not be charged to other Federal awards to overcome fund deficiencies, avoid restrictions imposed by Federal statutes, regulations, or terms and conditions of the Federal awards, or other reasons. However, this prohibition would not preclude the non-Federal entity from shifting costs that are allowable under two or more Federal awards in accordance with existing Federal statutes, regulations, or the terms and conditions of the Federal awards.
4. Direct cost allocation principles. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then, notwithstanding paragraph (c) of this section, the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Where the purchase of equipment or other capital asset is specifically authorized under a Federal award, the costs are assignable to the Federal award regardless of the use that may be made of the equipment or other capital asset involved when no longer needed for the purpose for which it was originally required. See also §§200.310 Insurance coverage through 200.316 Property trust relationship and 200.439 Equipment and other capital expenditures.
5. If the contract is subject to CAS, costs must be allocated to the contract pursuant to the Cost Accounting Standards. To the extent that CAS is applicable, allocating costs in accordance with CAS takes precedence over the allocation provisions in this part.

Definition of Some Cost

Pre-award costs  (§200.458) are those incurred before the effective date of the Federal award directly pursuant to the negotiation and in anticipation of the Federal award where such costs are necessary for efficient and timely performance of the scope of work. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency.

Scholarships and student aid costs. §200.466 (a) Costs of scholarships, fellowships, and other student aid programs at IHEs are allowable only when the Federal award is to provide training to selected participants and the charge is approved by the Federal awarding agency. However, tuition remission and other forms of compensation paid as, or in lieu of, wages to students performing necessary work are allowable provided that:

1. The individual is conducting activities necessary to the Federal award.
2. Tuition remission and other support are provided per the established policy of the IHE and consistently provided in a like manner to students in return for similar activities conducted under Federal awards and other activities.
3. During the academic period, the student is enrolled in an advanced degree program at a non-Federal entity or affiliated institution, and the student's activities in relation to the Federal award are related to the degree program.
4. The tuition or other payments are reasonable compensation for the work performed and are conditioned explicitly upon the performance of necessary work.
5. The IHE's practice is to compensate students under Federal awards and other activities similarly.
6. Charges for tuition remission and other forms of compensation paid to students as, or in lieu of, salaries and wages must be subject to the reporting requirements in §200.430 compensation—personal services and must be treated as direct or indirect cost in accordance with the actual work being performed. Tuition remission may be charged on an average rate basis. See also §200.431 Compensation—fringe benefits.

Training and education costs. The cost of training and education (§200.472 ) for employee development is allowable.

Transportation costs. Costs incurred for freight, express, cartage, postage, and other transportation services (§200.473) relating to goods purchased, processed, or delivered, are allowable. When such costs can readily be identified with the items involved, they may be charged directly as transportation costs or added to the cost of such items. Where identification with the materials received cannot readily be made, inbound transportation costs may be charged to the appropriate indirect (F&A) cost accounts if the non-Federal entity follows a consistent, equitable procedure in this respect. If reimbursable under the terms and conditions of the Federal award, outbound freight should be treated as a direct cost.

Travel costs. §200.474

1. General. Travel costs are transportation, lodging, subsistence, and related items incurred by employees who are in travel status on official business of the non-Federal entity. Such costs may be charged on an actual cost basis, on a per diem or mileage basis in lieu of actual costs incurred, or on a combination of the two, provided the method used is applied to an entire trip and not to selected days of the trip, and results in charges consistent with those normally allowed in like circumstances in the non-Federal entity's non-federally-funded activities and accordance with non-Federal entity's written travel reimbursement policies. Notwithstanding the provisions of §200.444 General government costs, travel costs of officials covered by that section are allowable with the prior written approval of the Federal awarding agency or pass-through entity when they are specifically related to the Federal award.
2. Lodging and subsistence. Costs incurred by employees and officers for travel, including costs of lodging, other subsistence, and incidental expenses, must be considered reasonable and otherwise allowable only to the extent such costs do not exceed charges normally allowed by the non-Federal entity in its regular operations as the result of the non-Federal entity's written travel policy.

Participant support costs (§200.75) are direct cost items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) concerning conferences or training projects.

• Per §§200.68, participant support costs (PSC) are excluded from the Modified Total Direct Cost (MTDC) base.
• Per §200.308 (b), transferring funds budgeted for participant support cost to other categories of expense requires prior approvals from Federal awarding agencies for budget and program plan revisions.

The budget awarded for participant support cannot be transferred to other expense categories unless approved in writing by the Program Officer.

• The budget can be moved into participant support costs.
• Re-budgeting between the defined participant support cost categories is permitted.

Participant support costs categories include: 

Stipend - A set amount to be paid directly to the participant. Conditions for receiving a stipend should be in writing and program completion attested to by the project PI.  Granting agencies may have specific guidelines for participant stipends.

Travel - Travel includes the costs of transportation and associated costs. It must follow sponsor guidelines (e.g., U.S. flag carrier, coach class, most direct route) as well as university policies and guidelines.  The sole purpose of the trip must be to participate in the project activity.  If a training activity involves additional field trips, the transportation costs of participants may be allowable.

NOTE: Field trips for recreational purposes are not permitted.

Subsistence -Housing and meal expenses necessary for the individual to participate in the project are generally allowed, provided these costs are reasonable and limited to the days of attendance. Although participants who live in the local area are not entitled to subsistence payments or per diem, they may participate in meals and refreshments provided at the meeting or conference.  

NOTES: Do not duplicate support for individuals covered by other federal funding sources.

While employees are not normally considered participants may receive conference meals under this provision.

Fees - Costs directly associated with attending conferences, symposia, or training projects. Such costs include registration, conference, and similar fees.

Other Costs - Certain other costs may also be allowable if consistent with university policy and practice and specified in the proposal approved by the sponsor upon review. 

Example: training materials or laboratory supplies were approved by the sponsor.

Costs that do not fall under Participant Support Cost (PSC):

• Guest speaker or lecturer fees.
• Conference support costs such as facility and audio/visual equipment rental.
• Service or independent contractor agreements.
• Incentives (prizes), memorabilia, or gifts.
• Employee compensation and expenses

(Note: Exception for employee meals; they are allowable where provided to all attendees of a sponsored conference.)

Important things to remember in managing Participant Support Cost (PSC):

• It is necessary that the Participant Support Cost is written as part of the funding opportunity or agency rules and specifically included in the proposal.
• Depending on the awarding agency, the conditions or constraints vary for re-budgeting awarded participant support funds.
• Re-budgeting will change the scope of the award and must have the agency's approval
• The addition of a participant program, where not previously awarded, is generally considered a change in scope requiring an agency’s prior approval.
• A separate account or sub-account is required when PSCs have been explicitly awarded.   Expenses beyond the budget should be in the already established participant support account/sub-account. A separate account/sub-account is not required where costs are allowed by the agency but not explicitly awarded.  

For samples of participant support acceptance letters click here 

For frequently asked questions regarding participant support, click here.

[78 FR 78608, Dec. 26, 2013, as amended at 79 FR 75885, Dec. 19, 2014]

Unallowable Costs

This section is not exhaustive and is intended as a quick reference for common types of costs. 

The following are examples of generally unallowable expenditures and are not all-inclusive.

Entertainment Costs
Costs incurred for amusement, social activities, entertainment, and related items include meals, lodging, rentals, alcoholic beverages, transportation, and gratuities.

Goods or Services for Personal Use
Costs of goods or services for the personal use of the institution’s employees, regardless of whether the cost is reported as taxable income to the employees.

Pre-Agreement Costs
Costs incurred before the effective date of the sponsored project, whether or not they would have been allowable if incurred after such date, are unallowable unless specifically set forth and identified in the sponsored agreement or approved through prior approval procedures.

Memberships In Civic or Community Organizations
The costs of an individual’s membership in civic or community organizations are not allowable—likewise, any social, dining, country club, or organization memberships.

Items Not Normally Treated As Direct Costs
The following items are normally included in facilities and administrative (F&A) costs. Direct charging of these costs may be appropriate where a major project or activity explicitly budgets for them and can be specifically identified with the project or activity. “Major project” is defined as a project that requires support that is significantly greater than the routine level of such services and or supplies provided by academic departments. Examples of items include:

• Administrative and clerical staff salaries.
• Office supplies, postage, local telephone costs, and memberships.

Please see the following links.

• 2 CFR 200.410 - Collection of unallowable costs, click here.
• NSF allowability of cost, click here. 
• NIH Allowability of Costs/Activities, click here.

CSU ensures that all cost is charged to the appropriate Federal grant, contract, cooperative agreement, or subaward when first incurred. However, there are circumstances where it may be necessary to transfer expenditures to a Federal award following the initial recording of the charge. A reallocation of cost from one fund to another is called cost transfer. When this happens, CSU maintains to follow all provisions stated in the notice of Grant awards and 2 CFR Chapter I, Chapter II, Part 200, et al., Uniform Administrative Requirements (Uniform Guidance - UG), Cost Principles, and Audit Requirements for Federal Awards is followed at CSU. The UG provisions include a requirement for CSU to relate financial data to performance data and to ensure such data is current, accurate, documented, and complete. These standards also require that accounting records which are supported by source documentation. This supporting documentation will assist in determining the reasonableness, allocability, and allowability of the cost in accordance with the terms and conditions of the award.

To initiate a cost transfer, the Grant Accountant must prepare a transfer request for submission to the appropriate accounting personnel. All cost transfers must be the same amount as the original charge unless the transfer is divided among different departments. If divided, an explanation of the division must accompany the transfer request. The department requesting the cost transfer must have incurred the item of cost and must identify the goods and services and their quantities in the transfer request. All cost transfers must be for allowable costs and must be made within 120 days of the end of the month in which the original charge is posted to the ledger.

The university identifies these recurring adjusting journal entries for posting to the general ledger in each accounting period. Nonrecurring adjusting journal entries must be prepared to reflect account balances properly. Nonrecurring adjusting journal entries include, but are not limited to, the following items:

1. Correction of posting errors - Correct clerical errors (such as typographical errors or transposition of account digits).
   1. Pre-Award Costs – At times, it is necessary to begin spending on a research award before receiving the award document
   2. Pre-award costs must be authorized in accordance with sponsor and University policies. Such costs must be charged to a department or discretionary account and transferred to the new award account when established.
   3. Transfer of pre-award costs should be made in a timely manner to ensure costs are recorded in the proper accounting period. However, they cannot be charged to the fund until it is in effect.
   4. Closely Related Projects – To meet this definition, the same PI must manage projects, scientifically and technically related, contain no change in the scope of the grant, the arrangement must not be detrimental to the effort approved under each award, and the relatedness must not be used to circumvent the terms and conditions of each individual award.
      1. When research on separate projects is closely related, costs that are allowable and allocable to either project may be incurred. 
      2. If, after charging an expense to one of the accounts, it is determined that all or part of the expense is more appropriately charged to a second account, the allocable portion of the expense can be transferred to the second account with a proper explanation.
   5. Cost Overruns
      1. As discussed above, it may only be transferred to another research account when the projects are closely related.
      2. Overruns that cannot be transferred to a related research account must be funded with non-federal funds. Such amounts must be properly accounted for as cost-sharing and included in the organized research base.
   6. Disallowed Cost – If a disallowance is identified, that cost must be transferred to an appropriate non-federal account.
   7.  Accrual of income and expense items
   8. Cost Transfers shall be supported by source documentation establishing:
      1. Timeliness
      2. Any cost transfers must be done in a timely manner based on sponsor guidelines but no more than 120 days of finding the error.

Important to Remember

• Adequate Documentation for All Journal Vouchers
• All journal vouchers for journal entries are prepared only based on adequate supporting documentation.
• Authorization of Entries
• All journal vouchers for entries into the general ledger are authorized and approved by the Chief Accountant or Director of Administration and Finance who is not involved in the origination of the entries.

In addition, the National Institutes of Health (NIH) Grants Policy Statement states:

“Cost transfers to NIH grants by grantees…should be accomplished within 90 days…transfers must be supported by documentation that fully explains how the error occurred and a certification

of the correctness of the new charge by a responsible organizational official of the grantee…” “An explanation merely stating that the transfer was made “to correct error” or “to transfer to a correct project” is not sufficient. Transfers of costs from one project…to the next solely to cover cost overruns are not allowable.”

“Grantees must maintain documentation of cost transfers, pursuant to 45 CFR 74.53 or 92.42, and make it available for audit or other review. The grantee should have systems in place to detect such errors within a reasonable time frame; untimely discovery of errors could indicate poor internal controls. Frequent errors in recording costs may indicate the need for accounting system improvements, enhanced internal controls, or both.”

Close-out

The final stage in the grant lifecycle is grant closeout.  This phase begins when the grant award period has expired or the Chicago State University draws down its entire grant award.  Federal awarding agencies will notify Chicago State University as it nears the end of its grant term to request final reports.  Suppose Chicago State University is nearing the end of its grant term but has not yet expended its entire grant award. In that case, it may be able to seek an extension from the federal awarding agency.

2 CFR Part 200 Sections 200.343 thru 200.345 give detailed guidance on grant closeout activities.  Generally, the federal awarding agency will request and review the following items within 90 days after the expiration of the grant award:

• Work plan and progress reports
• SF-269 Financial Status Reports
• Requests for payments
• Compliance with matching requirements
• Federally-owned property records

As the federal awarding agency conducts its review, it can still discover and collect payments for disallowed costs and other deficits in the grant administration. Please see the grant close-out form sample here.

GRANT CLOSE-OUT Procedure 20.6 – Grant Close-out Page 118

Please note that all subrecipient records and documentation, including risk assessments/evidences, are all kept in the department (OGRA) shared  R drive.

Why should we retain financial records?

• It provides those responsible for managing cost objects with the means to monitor transactions and resolve problems.
• It enables the Institute to comply with various requirements—Federal Acquisition Regulation (FAR), A-110, Uniform Guidance, IRS and other federal, state, and local regulations—which govern the auditing and retaining of records. Retention requirements are typically defined by the type of award (grant, contract, cooperative agreement) and the sponsor (federal, non-federal, foundation).
  • For federal awards that fall under OMB's Uniform Guidance, see a summary of the revised requirements for paper vs. electronic retention here: 
  • Uniform Guidance section: 200.335
  • Uniform Guidance section : 200.333
• For older federal grants and cooperative agreements, A-110 states that financial records, supporting documents, statistical records, and all other records pertinent to an award should be retained for three years from the date of submission of the final expenditure report; for awards that are renewed quarterly or annually, the records should be retained from the date of submission of the quarterly or annual financial report, as authorized by the federal awarding agency.
• For federal contracts, FAR dictates that records must be retained for three years after the final payment. This includes books, documents, accounting procedures and practices, and other data—regardless of whether such items are written, computerized, or in any other form—and other supporting evidence to satisfy the contract negotiation, administration, and audit requirements of the contracting agencies and the Comptroller General. For financial and cost accounts, pay administration and acquisition, and supply records, the required retention requirement is two to four years. 

Time of Retention

Generally, legal and audit requirements dictate how long financial and project records should be retained.

• When requirements for long-term records retention overlap, the responsible office should retain records for the maximum period needed to meet legal and audit requirements. A-110 specifies the following:
  • Direct charges to contracts and grants: Three years following the date CSU OGRA considers the project to have been formally closed by the sponsor, unless an audit or litigation is underway.
  • All cost objects included in the F&A cost rate: Three years following the federal government's final sign-off for that year. Contact the Office of Grants and Research Administration (OGRA) for further information.

Longer retention times apply to certain documents. See Retention of Copies for Department Files.

Scientific Data/Technical Records Retention

The Principal Investigator is responsible for retaining scientific and technical data and related compliance documentation.