Finance Procedures

Post Award Compliance Procedures

  1. Post-award Compliance Changes
  2. New Procedures Regarding Overdrafts and Accelerated Spending
  3. New Procedures Regarding Closeout/Financial Reporting Delays

The University through the Finance Department (Grants/Sponsored Projects, one of the Sponsored Projects Management Group(SPMG) established the Quarterly Post Award Reporting Policy and Procedure for the review and monitoring of sponsored project accounts.  The University is now requiring All Faculties to develop additional controls to ensure timely management of these accounts consistent with University policy as well as any sponsor requirements and governmental regulations.   The developed and established compliance processes are to address the following two issues:

  • Accounts that appear to have an accelerated spending pattern or have gone into overdraft

  • Timely submission of interim and final financial reports to the sponsors. This document addresses specific responsibilities of the Faculty/Institute/Department and the Office of Sponsored Project (OSP), Finance Department in the management of these two areas.

    1. OVERDRAFTS AND ACCELERATED SPENDING 

    • A report of potential over-expenditures above a threshold of $5,000 on awards and grants will be sent to each Faculty/Institute/Department with their copy of the Quarterly Report. 
    • The Faculty/Institute/Department must give a detailed explanation and, if applicable, an action plan to resolve the problem. Identified overdrafts/over-expenditure must be cleared within 30 days of the quarterly report due date. 
    • If not cleared within 30 days, Finance will provide the Faculty/Institute/Department account to OSP and OSP will prepare the journal with a cc to the Faculty/Institute/Department  

    2. CLOSEOUT AND INTERIM FINANCIAL REPORTING

    • Most sponsors require final financial reports within 90 days (sometimes less) from the project end date.

    •  Interim reports are generally required 90 days from the end of the reporting period. 
    • OSP will send a reminder 90 days prior to the end date that an award will be ending.  The Faculty/Institute/Department should be ready to close out the award 30 days after the end of the award. 
    • To initiate closeout, OSP will contact the department by email not less than 30 days after the end date of the award to verify if the award is ready to be closed.  In most cases, the email will also question any possible unallowable charges on the account. 
    • The Faculty/Institute/Department has 30 days from the date of the email to respond to OSP.  After 21 days, if they have not heard back from the Faculty/Institute/Department, OSP will call the Faculty/Institute/Department as a reminder of the upcoming 30-day deadline. 
    • Lack of a response from the Faculty/Institute/Department will indicate to OSP that they may proceed with closeout.  If possible unallowable charges were included in the email, they will be then be considered unallowable and moved off of the award. 
    •  Faculty/Institute/Department Accountant will provide OSP with a Faculty/Institute/Department account and OSP will prepare journals with a cc to the Faculty/Institute/Department.
    • Below is a matrix with further details concerning the procedures for these two compliance issues.  In addition, the Faculty/Institute/Department contact list that OSP uses is posted on its website at:

    3. New Procedures Regarding Overdrafts and Accelerated Spending 
     

     

    Issue

    Action

    Further Action

    Overdrafts Identified by OSP and SPMG

    The Overdraft Report will consist of apparent overdrafts of greater than $5,000.

    The report will be sent to the department with the Quarterly Reports.  Department must comment on each account and return comments with Quarterlies by the due date.  Identified overdrafts must be removed within 30 days of the due date listed on the cover memo.  If not removed within 30 days, OSP will move the overdraft to a Faculty/Institute/Department account identified by OSP/SPMG.

    For all overdrafts identified during financial reporting must be removed within 30 days of notification by OSP.  If not removed within 30 days, OSP will move the overdraft to a Faculty/Institute/ Department account identified by OSP

     

    The Faculty/Institute/Department Accountant may work with OSP to determine an alternate account for the overdraft from the one provided by Faculty/Institute/Department Accountant, if necessary.

    Accelerated Spending

    Most will be identified, and commented upon, as part of the Overdraft Report mentioned above. 

    Accounts identified as having accelerated spending will be dealt with on a case-by-case 
    basis.

     

  • Overdraft Reports (SPMG)

      • Faculty/Institute/Department must give a detailed explanation and, if applicable, an action plan to resolve the issue for each account that is listed on the Overdraft Report.
      • Journals prepared by OSP or Faculty/Institute/Department Accountant to move the overdrafts will have the Faculty/Institute/Department Chair copied on the journal.
      • A report listing Questionable and Administrative charges on sponsored projects will also be sent with the Quarterly Reports to the University Bursar/Director, Finance: attn, Manager, Grants and Sponsored Projects i.e. (OSP) for review and to advise University Bursar on the way forward.

        4. New Procedures Regarding Closeout/Financial Reporting Delays      

         

        Issue

        Action

        Further Action

        No answer from Unit on "Okay to Close" request

        Once contacted by OSP, The Unit/Faculty/Institute/Department  has 30 days to respond to SPRMG/OSP whether or not the award is ready to close.  After 21 days, OSP will call the Faculty/ Institute/Department  as a reminder if they have not had a response.  Lack of a response within those 30 days indicates that the award is ready to close and OSP will proceed with closeout.

        In the event a final invoice for a contract which is due within 45 days or less, the Faculty/ Institute/Department will respond promptly so that the deadline can be met.

        If expenses post to the award after the closeout is complete and final report has been sent, the charges will be moved to an appropriate Faculty/Institute/Department account (given to OSP by Faculty/Institute/Department Accountant 

        Possible Unallowable Charge(s) 

        Once contacted by OSP, Faculty/Institute/ Department  has 30 days to respond to request for information/justification or to remove the charge.  After 21 days, OSP will call the Faculty/Institute/Department  as a reminder if they have not had a response.  If no response from Faculty/Institute/Department  in 30 days, OSP will move the charge to a Faculty/Institute/ Department  account identified by OSP/SPMG

        Even if the charge is later determined to be allowable, it may not be transferred back onto the award (since OSP would have to revise the report).

        Award ended more than 120  days ago (and there is no NCX in process)

        OSP will proceed with closeout without Faculty/Institute/Department approval.  However, OSP will notify the Faculty/Institute/Department  that the final financial report is being prepared and sent to the sponsor.

        Any further charges must be charged to an appropriate department account.

        NOTE: OSP will not revise reports once the financial report has been sent to the sponsor (unless a credit  is posted to the account).

        5. Additional Information and Procedures:

        Closeout/Interim Financial Reporting Issues (OSP)

          • Initial contact will be via email to Faculty/Institute/Department by Manager, OSP/Accountant.  Emails will be sent to two Faculty/Institute/Departmental contacts (i.e. PI/PD and the Unit Accountant,both of which can make decisions.  A response from either contact  will be considered final.
          • OSP will not contact Faculty/Institute/Department any sooner than 30 days after the end date of the award.
          • "Okay to Close" and Possible Unallowable Charges requests will in most cases be sent in the same email.
          • The response must be an answer and not time extensions as time extensions will not be granted.
          • Exceptions to these procedures will be made on a case by case basis.       
      • Post-Award Compliance Checklist   

          • Charges to budget must comply with University and Sponsor rules .
          • Charges posted to a grant must be for:
          • Goods received or services rendered during the budget period.
          • Goods or services providing a direct benefit to that grant.
          • Charges must be approved by the PI/PD/Designee with direct knowledge of the needs of the project.
          • Charges split between more than one grant must be split on the basis of proportional benefit or other reasonable method (not funding).
          • Transfers of charges to or from a grant must be properly approved and processed within 120 days of transaction.
          • For charges related to items not in the approved budget, prior written approval must be obtained from Sponsor/Funding Agency if required and as stated in the Agreement.
          • Program Income must be identified and used in accordance with the terms of the award or by University and other Tertiery Institutions Act/Regulations. See Program Income Policies.
          • Charges for items that are normally indirect (administrative and clerical salaries, office supplies, toner cartridges, diskettes, basic local telephone services, cellular phones, pagers and related service charges, routine copying charges, memberships, and journals and subscriptions) can only be charged directly to on-campus Government grants or from Internally Generated Fund.
          • Charges that are not allowable must not be charged to grants or contracts.
      • Reporting and Reconciling
         

          • Charges appearing on the Budget Activity Reports must be reconciled to supporting documentation to ensure validity and accuracy. See Grant and Contract Closing Process.
          • At expiration, notify GCA, OSP within 45 days of pending charges or credits. 
          • Total expenditures must be compared to the budget on a periodic basis to identify any unplanned variances. 
          • Complete technical report and submit it by sponsor deadline. 
          • Complete property report and submit it by sponsor deadline.
          • Complete invention report and submit it by sponsor deadline. 
      • Documentation   

          • Faculty Effort Certification (FEC) must be filled out quarterly or Semi-annually to reflect actual effort, signed by Principal Investigator (PI) or Project Director (PD) and returned to Management Accounting and Analysis (MAA), OPS by due date. Department retains their copy of the FEC for 1 year after the end of the fiscal year.
          • Grant and Contract Certification Report of salaries must be reviewed for the appropriate assignment of salaries commensurate with the level of effort provided, signed, and retained in the department.
          • Signature authority may be delegated in writing by the PI/PD to those with direct knowledge of project in accordance with 
          • Mandatory cost sharing and committed cost sharing on proposals submitted must be reported no less frequently than quarterly and documented in full within 45 days of expiration of the budget period. 
          • Documentation in support of expenditures must be retained in accordance with the University Records Retention Policy.
                 

      • Separation of duties

        • No one person has complete control over all aspects of a financial transaction. Ideally, no single individual should be able to:      
        1. Authorize a transaction
        2. Account for the transaction and
        3. Have custody of the asset relating to the transaction