Non Financial Compliance
Expense Management- General
Expense Management- Non-Payroll Activity
Expense Management-Payroll Activity
Matching Funds/In-Kind Contributions
Managing a Grant Award: Post-Award Set-up
Upon award, a grantor may send notification to the Principal Investigator (PI), the ORSP, the Controller’s office, or the Vice President for Academic Affairs. If notification of an award is sent to the PI, it should be forwarded immediately, along with all accompanying information, to the ORSP. The ORSP will review the terms and conditions of the award, ensuring that they are acceptable to the University. The ORSP may contact the PI during this process, and the PI should raise any questions or concerns that he or she may have, as the University is in a position to negotiate the terms of the agreement before it is signed.
The PI may not sign a grant award or contract. Forward such documents to the ORSP for signature by the appropriate authorized personnel.
In the case of grants awarded by certain private foundations, the Office of Corporate & Foundation Relations is responsible for overseeing that appropriate University approvals are obtained.
ROLES AND RESPONSIBILITIES:
The Principal Investigator is the project lead. He or she is responsible for the appropriate conduct of the project in accordance with the terms and conditions of the grant and University policies. It is the ultimate responsibility of the PI to ensure all expenditures charged to the grant are allowable and are relevant to achieving the grant’s objectives.
The University, primarily through the ORSP and the Controller’s Office, is responsible for ensuring that PIs have the support and knowledge of grantor requirements so as to perform the project in accordance with grantor regulations. While the ORSP does not oversee financial reporting, it assists the faculty members in interpreting the grant terms and conditions, facilitates compensation payments, authorizes changes to be made in accordance with agency rules and requirements, and monitors project performance. The ORSP should be contacted whenever changes are required as ORSP staff will provide guidance on approvals that may be required and facilitate any required changes. The Controller’s Office and other departments within the Finance Division perform accounting and financial reporting functions to provide the infrastructure needed to ensure that the grantor’s funds are managed in accordance with fiscal requirements and federal regulations, including that spending is in accordance with the approved budget, grantor requirements, and grant period.
Once a sponsored project agreement has been fully executed, the ORSP will complete the Grant/Contract Award - Account Set-up Form and forward it to the Controller’s Office with other relevant documents. The Grant/Contract Award - Account Set-up Form details the approved budget for
the project and provides other information important to the establishment of an account and monitoring of the project.
The following materials will be distributed to the PI and the Controller’s Office:
• Account Set-up Form
• Notice of Award Document/Contract
• Final Proposal
• Grant Terms and Conditions
Each grant will be assigned a major code (department code) to help maintain and track costs within the University’s accounting system. It is the responsibility of the PI to maintain and monitor these accounts on at least a monthly basis. The MyBudget application available via InsideLoyola will assist in this process by providing real-time fiscal information. It is an easy way to view the approved budget and compare it to the expenditures that are charged to the grant account so that the PI and/or designee may verify the accuracy of the charges applied to the grant. For training in the use of MyBudget or concerns related to the grant activity, the PI should contact the Controller’s Office.
The ORSP will convene a meeting with the PI and the Controller’s Office to discuss the management of the new award. The meeting provides an opportunity to cover key compliance issues, to educate the PI on the types of information that he or she can expect to receive from the Controller’s Office, as well as to answer questions such as who to contact for assistance. The PI is encouraged to invite support staff or others who may provide assistance with ordering grant-related materials, making grant-funded travel arrangements, etc.
INDIRECT COST DISTRIBUTION:
As defined by federal regulations, indirect costs, also known as Facilities and Administrative Costs, are costs that are incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular sponsored project, an instructional activity, or any other institutional activity.
To promote sponsored research activities, the University shares 20% of the indirect cost recovery associated with a successful grant proposal with the department of the PI. An additional 20% of indirect cost recovery is shared with the department’s dean. When the grant account is established, the Controller’s Office forwards information to the Director of Resource Management who transfers the requisite funds into an account established for the department and the dean. Indirect costs are distributed at the beginning of the grant and carry over from year-to-year.
SPECIAL NOTE RELATED TO CERTAIN CONTRACTS:
Generally, once an account has been established and the grant period started, the PI may draw on the account. However, for certain business relationships, especially those related to sub-awards, subcontracts, and certain partnerships/letters of agreement/contracts, additional approval must be obtained to ensure the University is legally protected and the business partner/vendor agrees to certain University policies. This will be discussed during the preliminary meeting.
Managing a Grant Award: Non-Financial Compliance
PIs must adhere to University policies and procedures for non-financial compliance issues. The most common of these is the requirement to obtain approval for research involving human participants. Information on Loyola’s policy and procedures for research involving human participants is found on https://inside.loyola.edu/academics/research/orsp/compliance.
Managing a Grant Award: Financial Compliance
Loyola’s policy is to adhere to generally accepted accounting principles including the provisions of OMB 2 CFR 200, commonly known as the Uniform Guidance as required. The overriding principle for financial management of grants, particularly government grants, is to ensure that all charges are:
- consistent with: the Uniform Guidance, agency-specific requirements, award documents, and institutional policy
- necessary for the performance of the project and in an amount that would be deemed reasonable for business conduct
- incurred solely to advance the work of the grant
- treated in the same manner regardless of the source of funding
The information on budget development aligns with the Uniform Guidance, which provides guidelines on the allowability of costs.
In addition, the following links provide detailed information on the costing principles and grant management requirements required by the federal government and selected federal agencies:
When PIs have questions concerning these guidelines they should contact the ORSP.
Managing a Grant Award: Expense Management - General
The PI is responsible for initiating payments to be made from the grant. It is important that financial transactions be processed on a timely basis. Project-related expenses should be charged directly to the grant account.
Frequent journal entries that transfer expense to or from a grant account and/or major deviations from projected spending patterns may raise grantor concerns about financial accountability.
See below for more detail.
The PI must monitor the grant budget and spending activity closely so as to not spend more than is available. To minimize this possibility, if the grant is overspent, the PI will be notified by the Controller’s Office. Excess expenses are not allowable and must be moved to another funding source. Grant accounts may be frozen at this time.
If during the grant period the PI needs to reallocate funds originally approved by the funding agency, they should first contact the ORSP for approval. If applicable, the ORSP will contact the funding agency for any additional approval needed. Once approved by the ORSP and/or grantor, the ORSP provides documentation to the Controller's Office via email, if needed. If required by the granting agency, the ORSP will work with the PI to ensure a Budget Adjustment Form is submitted to the Controller's Office.
Cost transfers/corrections are adjustments made via journal entry to transfer expenses from one account to another. They are necessary when an expense has been mischarged. Regulations require that cost transfers are well documented and be made on a timely basis. Further, these manual adjustments are an area of focus for auditors. The following are potential red flags:
- Cost transfers which charge a grant account toward the end of a project
- Cost transfers that move charges from one grant account to another
- Cost transfers which do not contain a detailed explanation
- Cost transfers made more than 90 days after the date that the expenditures was originally charged to an account
- An excessive number of cost transfers
PIs should scrutinize their grant account on a regular basis so that any necessary corrections can be made on timely basis. When a cost transfer is necessary, the PI should submit an Expenditure Transfer Form to the ORSP for review with a complete explanation as to why the transfer is necessary. An explanation such as “to move the expense to account xxx” is not acceptable. The PI should include all applicable back up associated with the transfer (i.e. MyBudget screen shots of the charge(s), invoices, correspondences, etc.) when sending the form.
The ORSP will then submit to the Controller's Office.
The Controller’s Office will review the cost transfer to ensure it aligns with grantor regulations before processing the transaction.
MONTHLY REVIEW OF GRANT ACTIVITY:
PIs are responsible for reviewing their grant activity monthly. The MyBudget application available via InsideLoyola is critical to achieving this task by providing real-time fiscal information on-demand. PI’s should review it to ensure that expenses posted to the grant are appropriate and that all expenses expected are included. The PI is responsible for contacting the Controller’s Office if adjustments are needed or if there are questions related to the financial transactions.
Managing a Grant: Expense Management - Non-Payroll Activity
Grant purchases follow the same process as purchases made using non-grant resources. They may be made via invoices, petty cash advances, reimbursement requests, or use of a procurement card; see the Accounts Payable website for the University’s policies and procedures surrounding these transactions. The PI is responsible for ensuring that each purchase is in compliance with all Grant and University spending policies.
DEBARMENT AND SUSPENSION POLICY:
Government funds may not be used to pay vendors or contracts with certain parties who are debarred, suspended or otherwise excluded from or ineligible for participation in Federal Assistance programs or activities, as listed on the U.S. Federal Government's Excluded Parties (Vendor) list. Loyola policy is to not procure goods or services or make contract purchases from an entity or individual included on the debarment list. The Accounts Payable Office verifies that all new vendors are not included in the listing and makes periodic checks of existing vendors to ensure that they are not in the excluded vendor list. Contracts or sub-awards made to a sub-grantee will include a certification clause regarding its exclusion status and that of its principal employees from the federal debarment list.
GRANT PROCUREMENT POLICY:
OMB Circular A-110, section .43 requires that procurement transactions are conducted in a manner to provide, to the maximum extent practical, open and free competition.
As such, for grant purchases:
- up to $25,000 PI may make discretionary purchases without formal competition.
- $25,000 to $100,000 Written records must be maintained documenting the basis for vendor selection as well as a minimum of three written or verbal quotes.
- $100,000 or greater Written records must be maintained documenting the basis for vendor selection as well as a minimum of three written quotes.
University approval would need to be obtained in accordance with Loyola’s Signature Authorization Levels for Purchasing Policy.
The University will be reviewing its procurement practices in order to be compliant with the requirements of the purchasing requirements of the Uniform Guidance which will be effective June 1, 2017.
Ownership of grant-funded equipment vests with Loyola. If a PI should separate from Loyola and pursue employment at another institution, Loyola would retain the equipment. Equipment purchased with grant funds may not be disposed of or used for other projects (the latter, during the award period) without clearance from the funding agency. The ORSP would contact the agency for this clearance.
Grant-funded equipment is subject to inventory control procedures similar to that of other capital assets. Physical inventory observations will be conducted regularly throughout the life of the equipment, regardless of the grant end date.
SUBCONTRACTS, SUB-AWARDS, PARTNER AGREEMENTS:
The ORSP will oversee the development and execution of subcontracts and sub-agreements for all grants/sponsored projects. Payments may not be processed to subcontractors or sub-awardees before fully executed documents are in place. These agreements must contain an assurance that the outside entity will abide by the terms and regulations established by the federal government or other sponsor and that they are not debarred or suspended from doing business with the federal government. Before approving an invoice for a subcontractor or other partner, the PI is responsible for ensuring that the corresponding work has been satisfactorily completed.
Payments to outside consultants, partners or sub-awardees must be made on a cost reimbursement basis unless otherwise provided for in the written agreement between Loyola and the outside entity.
Loyola’s policies and procedures for travel are located on the Accounts Payable webpage. Note that the Fly America Act requires use of US flag air carriers for government-funded foreign travel when available. Contact Accounts Payable for guidance in meeting this requirement. If travel includes requests for reimbursements for meals the PI must ensure that alcoholic beverages are not charged to the grant.
Managing a Grant Award: Expense Management - Payroll Activity
HIRING GRANT PERSONNEL:
Grant budgets may include salary funding to allow the University to hire additional personnel to help fulfill the grant’s objectives. This could include full-time or part-time faculty or staff and student employees. When hiring a student, the PI should adhere to the University’s standard procedures, as established by the Human Resources Generalist Services group. In the case of employees other than student workers, the PI should have the Chair initiate a Position Announcement Authorization Form. Each potential candidate would be required to go through the University’s standard employment screening, hiring, and training processes. Once a candidate is selected, the PI would work with the Director for Human Resources Information Systems to set up the proper position identification number. It is the PI’s responsibility to monitor and ensure the new employee is working in accordance with grant specifications.
Grant budgets may include stipend funding which provides for supplementary compensation paid to current employees of the University for absorbing additional responsibilities associated with the grant. Typically, payment is in the form of summer stipends.
Payments to Loyola grant-funded personnel must coincide with the period of performance. The PI should notify the ORSP via email before work commences to initiate a stipend payment. The ORSP will submit the stipend request via the Web Stipend Entry Form available through WebAdvisor.
Faculty members should request summer compensation no later than early May. Following the period of performance effort reporting will be required to document that the compensation was appropriate to the level of work performed.
In some cases, for small stipend amounts, it may be preferable to pay an employee for grant-related work when the task has been satisfactorily completed.
Grant budgets may include salary support, generally to allow a PI to reduce his/her course load to allow for the time needed to perform the research or programmatic tasks funded by the grant. While approval of the course release occurs during the grant application routing process, the actual timing of the course release must be scheduled once the grant is awarded. Notification via email must be provided to the ORSP by the faculty member by September 30th for the fall semester and by December 1st for the spring semester so that course releases can be appropriately charged to the grant. The ORSP will complete the Grant-funded Course Release Form indicating that the appropriate charges can be directed to the grant and forward it to Assistant Vice President for Academic Operations, who then sends the Expenditure Transfer Request to the Controller’s Office. The Controller’s Office will reallocate this expense from the PI’s department to the grant during the semester the course release is used. The PI is responsible for maintaining accurate time and effort records to support their course release.
TIME AND EFFORT REPORTING:
It is critical to maintain accurate records to support the payment to each individual working on the grant, including the PI. These records may be in the form of effort reporting, which provides after-the-fact confirmation of the percentage of effort spent on government grants. If effort reporting is not required by the grant, the Employee Payment for Services Form may be sufficient if properly detailed; however, supplementary records (if kept) should be maintained to support the payment as it relates to the grant’s objectives in the event the grantor requires additional details.
Effort reporting must be completed for all professional personnel who are included in the budget request for a grant or whose contribution is provided as an in-kind contribution. A report must be filed at the close of each academic semester and at the end of the summer. The Controller’s Office is responsible for monitoring effort reporting and ensuring that charges for personnel do not exceed the effort expended over the course of the grant. They will provide the PI with copies of the required effort reporting forms at the start of the project. The PI is responsible for ensuring that effort reports are completed by the personnel (including the PI) who are working on the project. Each individual working on a project will confirm his/her effort on the project as required by the form. If necessary, the PI may serve as a confirming signature for project personnel so long as he or she has direct knowledge of an individual’s effort on a project. The PI will forward the form(s) to the Controller’s Office for each time period during which the project is active. Should the percentage of total effort expended on a project be less than had been requested, resulting in an overpayment to the individual, the employee will be required to refund the excess compensation. For instance, if the grant funds a payment equal to one month’s salary, or 20% effort during the semester and the actual effort is less than 20%, the difference is not allowable on the grant. Depending on the circumstance, the excess expense may be applied to the department budget (if the employee is under contract or the department approves). In some circumstances, the employee may be asked to refund the difference.
PAYROLL DETAIL IN MY BUDGET:
Due to the sensitivity surrounding employee salary information, payroll details by specific employee are not accessible in MyBudget; rather, it is broken out by pay period. If in reviewing the payroll totals by pay period differences between actual and expected are noted, please request the payroll detail by employee from the Controller’s Office.
Managing a Grant Award: Agency Funding/Reimbursement
Federal grant funding is typically received on a reimbursement basis, whereas private foundation grants are received in a lump-sum payment up-front, on a reimbursement basis, or based on a prescribed payment schedule. The Controller’s Office is responsible for invoicing the grantor in accordance with the grant terms and will rely on the accounting records in MyBudget. It is the PI’s responsibility to ensure that the activity reflected in MyBudget is correct in order to ensure accurate reporting and invoicing. For performance-based fixed-price payment arrangements, it is the PI’s responsibility to notify the Controller’s office that tasks are completed and eligible for billing in order for an invoice to be generated.
Managing a Grant Award: Matching Funds/In-kind Contributions
During the pre-award phase in the grant proposal and routing process, matching funds and in-kind contributions may have been committed to a PI or sponsor and included in the grant proposal as additional in-house funding to support the grant’s objectives. Because the University is held accountable to fulfill the commitment, quantified matching funds and in-house contributions are formally tracked in the accounting system.
The PI will work with the Controller’s Office to develop a plan to accurately track the additional resources at the onset of the grant. For each expense incurred by the department that can be applied to meet the matching commitment, the PI will be responsible for providing the Controller’s Office with supporting documentation. For non-payroll matching funds, a copy of the charges that can be applied (invoice, MyBudget detail, etc.) and the GL account number the charge was applied to is needed. For in-kind contributions related to employee services, time sheets and detailed descriptions of work performed should be provided. Cost share that is obligated for one grant may not be obligated for another grant.
Managing a Grant Award: Program Management
Programmatic Reports provide an important opportunity to communicate the positive outcomes that have resulted from a project funded by an outside agency or organization. Through describing what has been accomplished, a programmatic report fulfills a requirement of the outside agency but also helps to build confidence in the ability of the PI and the University to perform effectively in the future. Further, some agencies will withhold funding from PIs and organizations if reports have not been submitted. Therefore, it is critical that PIs develop and timely submit carefully prepared reports. The ORSP is available to assist with the development of these reports. For grants obtained with the assistance of the Office of Corporate and Foundation Relations (OCFR), the OCFR, the PI, and the ORSP will collaborate as needed. If financial information is required as part of the report, it must be obtained from the Controller’s Office.
Unless the report is publicly available on-line, a copy of each progress report must be forwarded to the ORSP.
Some government agencies require that publications that result from a grant be made available to the public by posting the document on-line at a specific government-maintained website. Publications may need to acknowledge the grantor while including a disclaimer about the information contained in the publication. Guidance will be available in the grant award and grant management documents. Additional guidance may be obtained from the ORSP.
Some grants will allow for grant period extensions. One-year no-cost extensions as well as formal extension request applications must be approved by the University. All grant extension requests should be completed 60 days prior to the original grant end date, or earlier if noted in the grant’s terms and conditions. The ORSP will work with the PI to develop the extension request. If the PI receives approval of an extension request directly, it must be forwarded to the ORSP with a copy to the Controller’s Office so that the grant deadline can be adjusted.
MAJOR PROJECT CHANGES:
Significant changes to a project, such as: change in scope, PI, PI’s effort, subcontracts, etc., may require communication with the grantor. Contact the ORSP for guidance on how to proceed.
Managing a Grant Award: Approaching Close-Out
The final months of a grant project are crucial to its successful completion. From a financial standpoint, it is crucial that all charges incurred during the project period are reasonable, allowable, allocable, and consistent with the policies established by the grantor and University as well as federal requirements.
During the final months of the grant, the PI should undertake a final review of all expenditures to ensure that all are appropriate. The PI should ensure that all financial transactions, programmatic reports, and other grant-related requirements are accomplished according to the deadlines required by the project sponsor. In so doing, the grant may be closed-out on a timely basis with minimal surprises.
Managing a Grant Award: Post-Projection Completion
The Controller’s office will close the grant in the accounting system 60 days after the project end date or earlier if specified by the grant documents. Expenses outside the grant period are not allowable and will be moved off the grant. In addition, if the grant is overspent, the expenses incurred in excess of the grant award amount are not funded and must be moved off the grant. These unallowable expenses will be applied to the PI’s department budget, unless an alternate funding source is identified by the PI.
Records pertinent to a sponsored project must be retained for a period of seven years from the date of submission of the final fiscal or program report (whichever is later). The PI should retain all programmatic reports, copies of research records, fiscal support records and other pertinent documents in the event that the grant is audited. The Finance Department retains records of financial transactions processed.
In order to comply with the Uniform Guidance, annually auditors will select a sample of federally funded programs and grants. In addition, each funding agency may elect to have their respective grant audited within seven years of the final report, or as specifically outlined in the Award Agreement or contract. If the PI is contacted for an audit, the PI should contact the Director of ORSP to ensure the audit is facilitated efficiently and appropriately. If a grant is under audit, the ORSP and Controller’s Office will facilitate the review and generally have a significant portion of the requested documents; the PI will be responsible for responding to all other questions and to provide supporting schedules as requested.