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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).
- 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. Once the Faculty/PI submits the ISP, the form is routed for approval.
OGRA sets up the Faculty/PI as a project manager in the project workspace in Grants.Gov.
- 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.
- As soon as the ISP is approved, if a Subrecipient is identified, the Grants and Compliance
Specialist (GCS), 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.
- 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 the majority
of 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.
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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 in, 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 person
or entity that is actively opposing U.S. or coalition forces involved in a contingency
operation (where members of 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 will be required to work with OMB to assist entities that
will be affected by this provision. If you are concerned that your organization may
have entered into contracts that would be prohibited by this provision, be sure to
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 is also applicable
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 extension 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 with the intent to streamline the federal grant-making and monitoring process,
to ease administrative burden for grant applicants and recipients, and to 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 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. 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 the administration of 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) PDF (55 pages, 220kb)
- A-122: This Circular establishes principles for determining 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 are covered by OMB Circular A-87, "Cost Principles
for State, Local, and Indian Tribal Governments"; or hospitals. The principles are
designed to provide that the Federal Government bear 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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 General Policy
Public Health Service Research Awards Policy
Financial Conflict of Interest Form
This policy confirms Chicago State University's commitment to the basic values of
openness, academic and scholarly integrity, and integrity of business policy and procedure,
independence, and safe and ethical research, as well as to its tradition and expectation
that employees will conduct their relationships with the University with candor and
integrity. To ensure the integrity of all institutional activities, including review
and conduct of research involving human and vertebrate animal subjects, and the associated
fiscal, contractual and procurement transactions, regardless of the source of support,
Chicago State University has elected to apply this Financial Conflict of Interest
policy to all University personnel.
In addition to supporting these basic values, this policy is also designed to:
- Satisfy federal regulations requiring the University to establish and implement policies
concerning Significant Financial Interests held by:
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- Employees or Investigators engaged in research funded by certain federal agencies
[e.g., Public Health Services (Title 42 CFR Part 50, Subpart F and 45 CFR Part 94)
and the National Science Foundation (Award and Administration Guide)],
- Institutional Review Board members (Title 45 CFR Part 46.107(e)), and
- Certain personnel involved in research involving human subjects funded by the Department
of Health and Human Services.
Such policies allow the University to maintain eligibility for federal funding from
the Public Health Service and the National Science Foundation and, in the case of
research involving human subjects, funding from any federal agency that is a signatory
to the Common Rule (Title 45 CFR 46) when researchers have Significant Financial Interests
in research involving human subjects.
- Protect researchers and other employees from misplaced charges of Financial Conflicts
of Interest by providing a mechanism for prior objective review and approval of Financial
Interests.
Chicago State University acknowledges that employees, and their families and dependents,
have the right to acquire, retain and accumulate personal financial assets (including
personal income from the transfer of technology or intellectual property subject to
University policy) and to establish financial relationships with outside private entities.
However, each employee also has the responsibility to manage his or her financial
affairs and relationships in a manner that does not interfere with, or improperly
influence the performance of, his or her duties and responsibilities as an CSU employee.
Chicago State University will exercise oversight and care in eliminating and managing
Financial Conflicts of Interest that do or may arise because of an employee's or an
investigator's financial Interest in the University activities or research activities.
The University will not accept or enter into agreements, contracts, gifts or purchases
that give rise to a Financial Conflict of Interest unless the conflict can be eliminated
or appropriately managed through administrative oversight to protect the interests
of the University. CSU will comply with all reporting responsibilities imposed by
the state of Illinois or federal laws or regulations with respect to financial interests
that have been disclosed while protecting the personal privacy of employees when possible,
except where disclosure is required by applicable law or this policy. The University
will comply with all federal and state statutes and regulations requiring reporting
of or public access to disclosed individual financial interests and Financial Conflicts
of Interest; however, the University will maintain the specific fiscal details of
this disclosed financial information as confidential information to the extent allowed
by applicable laws or regulations.
In effort of CSU’s employees fulfilling his or her responsibilities, and to assist
the University in avoiding or managing Financial Conflicts of Interest, each employee
and investigator must disclose any known Financial Interests that he, she or a dependent
has in any of the following:
- Any University purchase or procurement of goods or services (whether or not pursuant
to a formal contract) or in any investment or loan made by the University.
- Proposals that are submitted to external sponsors for funding in his or her institutional
responsibilities.
- Protocols for research that are submitted for review and approval by a regulatory
committee (or to a subcommittee).
- Any agreement relating to University technology or other intellectual property that
is or will be subject to negotiations between the University and any third person
or entity.
- A donor that contributes a monetary gift or gift-in-kind designated to be in support
of the employee’s scholarly activities.
- For an employee who is a member of any regulatory committee, any financial interest
that he or she has in any research protocol submitted to that regulatory committee
(with the Employee also recusing himself or herself from the review process regarding
such protocol).
- For an employee who is an investigator, any significant financial interest that he
or she has not already disclosed as a financial interest.
Such disclosures must be made annually and within 30 days of discovering or acquiring
a new Financial Interest.
An employee or Investigator who fails to make disclosures required by this policy,
or who otherwise violates any of the provisions in this policy, may be subject to
appropriate sanctions, including but not limited to, discipline for misconduct and/or
insubordination under the University policies, practices and procedures, up to and
including dismissal.
An employee or investigator who disagrees with a decision regarding the existence
of as Significant Financial Interest, Financial Conflict of Interest or the necessary
elements of a conflict management plan may submit a written appeal to CSU.
Chicago State University encourages faculty authorship of instructional materials
and does not discourage the use of such materials in courses in a faculty member's
department. In order to prevent Financial Conflicts of Interest or the appearance
of such in selecting instructional materials, every academic department or school
must have a policy appropriate to its circumstances that ensures instructional materials
are selected for their academic merit.
Situations involving Financial Interests also may involve issues addressed in the
University's policy on among others. Employees must comply with these and all other
applicable policies and regulations.
Tutorial on Financial Conflict of Interest is available click here.
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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 the allowability,
allocability, and reasonableness of an expense. 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 in order to be allowable under Federal awards:
- Be necessary and reasonable for the performance of the Federal award and be allocable
thereto under these principles.
- Conform to any limitations or exclusions set forth in these principles or in the Federal
award as to types or amount of cost items.
- Be consistent with policies and procedures that apply uniformly to both federally-financed
and other activities of the non-Federal entity.
- 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.
- 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.
- Not be included as a cost or used to meet cost sharing or matching requirements of
any other federally-financed program in either the current or a prior period. See
also §200.306 Cost sharing or matching paragraph (2).
- 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. The question of reasonableness is particularly
important when the non-Federal entity is predominantly federally-funded. In determining
reasonableness of a given cost, consideration must be given to:
- 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.
- 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.
- Market prices for comparable goods or services for the geographic area.
- 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.
- 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
- A cost is allocable to a particular Federal award or other 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:
- Is incurred specifically for the Federal award;
- 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
- 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.
- 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.
- 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,
to avoid restrictions imposed by Federal statutes, regulations, or terms and conditions
of the Federal awards, or for 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.
- 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.
- 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, the allocation
of 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 prior to 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 programs of student aid at IHEs
are allowable only when the purpose of 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:
- The individual is conducting activities necessary to the Federal award.
- Tuition remission and other support are provided in accordance with established policy
of the IHE and consistently provided in a like manner to students in return for similar
activities conducted under Federal awards as well as other activities.
- During the academic period, the student is enrolled in an advanced degree program
at a non-Federal entity or affiliated institution and the activities of the student
in relation to the Federal award are related to the degree program.
- The tuition or other payments are reasonable compensation for the work performed and
are conditioned explicitly upon the performance of necessary work.
- It is the IHE's practice to similarly compensate students under Federal awards as
well as other activities.
- 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 ) provided for employee development is allowable.
Transportation costs. Costs incurred for freight, express, cartage, postage, and other transportation services
(§200.473) relating either to goods purchased, in process, 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 cost may
be charged to the appropriate indirect (F&A) cost accounts if the non-Federal entity
follows a consistent, equitable procedure in this respect. Outbound freight, if reimbursable
under the terms and conditions of the Federal award, should be treated as a direct
cost.
Travel costs. §200.474
- General. Travel costs are the expenses for 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 in accordance with non-Federal
entity's written travel reimbursement policies. Notwithstanding the provisions of
§200.444 General costs of government, 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.
- 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 costs items such as stipends or subsistence allowances, travel allowances,
and registration fees paid to or on behalf of participants or trainees (but not employees)
in connection with 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) transfer of funds budgeted for participant support cost to other
categories of expense require prior approvals from Federal awarding agencies for budget and program plan revisions.
Budget awarded for participant support cannot be transferred to other categories of
expense unless approved in writing by the Program Officer.
- Budget can be moved into participant support costs.
- Re-budgeting between the defined participant support cost categories is permitted.
Participant support costs categories includes:
Stipend - A set amount of money 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 and 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 costs of transportation of participants may be allowable.
NOTE: Field trips for recreational purpose are not permitted.
Subsistence -The cost of 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: BE MINDFUL not to duplicate support for individuals covered by other federal
sources of funding.
While employees are not normally considered participants, they 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 Cost - Certain other costs may also be allowable if consistent with university
policy and practice, and specified in the proposal approved by sponsor upon review.
Example: training materials or laboratory supplies where approved by the sponsor.
Costs that does 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 and part of the funding
opportunity or agency rules and specifically included in the proposal.
- Depending on the awarding agency, the conditions or constraints varies for re-budgeting
awarded participant support funds.
- Re-budgeting will change the scope of the award and must have the agency approval
- Addition of a participant program, where not previously awarded, is generally considered
a change in scope requiring an agency’s prior approval
- The use of a separate account or sub-account is a required when PSCs have been explicitly
awarded. Expenses beyond the budgeted amount should be in the already established
participant support account/sub-account – A separate account/sub-account is not required
where costs are allowed by agency but not explicitly awarded.
Samples of participant support acceptance letter click here
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 any related items
such as meals, lodging, rentals, alcoholic beverages, transportation, and gratuities.
Goods or Services for Personal Use
Costs of goods or services for 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 prior to 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
Costs of an individual’s membership in civic or community organizations are not allowable,
likewise memberships in any social, dining, country club or organization.
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 which 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.
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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 maintain 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 includes 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 appropriate accounting personnel. All cost transfers must be in
the same amount as the original charge unless the transfer is being 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 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 properly reflect account balances. Nonrecurring adjusting journal
entries include, but are not limited to, the following items:
- Correction of posting errors - Correction of clerical errors (such as typographical
errors or transposition of account digits).
- Pre-Award Costs – At times it is necessary to begin spending on a research award prior
to receiving the award document
- 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 then transferred
to the new award account when established.
- 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.
- Closely Related Projects – In order to meet this definition projects must be managed
by the same PI, 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.
- When research on separate projects is closely related, it is possible that costs will
be incurred that are allowable and allocable to either project.
- 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 proper explanation.
- Cost Overruns
- May only be transferred to another research account when the projects are closely
related as discussed above.
- Overruns which cannot be transferred to a related research account must be funded
with non-federal funds and such amounts must be properly accounted for as cost sharing
and included in the organized research base.
- Disallowed Cost – If a disallowance is identified, that cost must be transferred to
an appropriate non-federal account.
- Accrual of income and expense items
- Cost Transfers shall be supported by source documentation establishing:
- Timeliness
- 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 on the basis of 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
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 must 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 be an indication of poor internal controls. Frequent errors
in recording costs may indicate the need for accounting system improvements, enhanced
internal controls, or both.”
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Close-out
The final stage in the grant lifecycle is grant closeout. This phase begins when
either the grant award period has expired, or when 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. If Chicago State University is nearing the end of its grant term but has not yet expended its entire grant award,
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 administration of the grant. Please see 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.
Grant Close-out Checklist Template, click here.
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:
- 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 account, 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 retention of records 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 under way.
- All cost objects included in the F&A cost rate: Three years following the final sign-off
for that year by the federal government. For further information, contact the Office
of Grants and Research Administration (OGRA).
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
as well as for related compliance documentation.
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