When SPS receives notice from GCS, SPS will authorize a new
FUND AREA ORGN for that project.
SPS requires:
- An Official Award
- Activation Notice
- Start and End Dates
- Budget
- Cost Share Information (if applicable)
- Indirect Cost Information
- Budget Restrictions
- Whether it is Fixed Price or Cost Reimbursable
- Reporting and Invoicing Requirements
- Contract Number and/or Purchase Order Number
- Catalog of Federal Domestic Assistance number, if the
project is Federally funded
- The Project Title
- The Principal Investigator, (ORGN Manager)
Once this information is received, SPS will set up a new
account number or new FUND AREA ORGN. The tables SPS uses are
FUND, ACT2, ORG2, FGY2, and GDES(2). In addition SPS activates an AA
document for APPR and APP2, ASUM an EB document for EXPB, EXP2, ESUM and an RB document for
REV2, RSUM and REVB tables.
Through the information SPS provides on these tables, SPS can
place certain restrictions and controls which help in
administering the account.
At the point when an account is authorized and activated on
the Financial Information System (Advantage), it is ready to be used. It is important to keep
in mind that each grant or contract account is different.
Different restrictions on accounts will affect the manner in
which your department and the P.I. will use them.
Budgets play a key factor. Some funding agencies are very
restrictive in the use of funds.
Budgets are required for each account. Employees in the
departments who work on the accounts should become familiar with
the restrictions or allowances that are associated with each
budget. Budgets are set up on a budget category basis. Examples
of categories are:
- Salary and Wages
- Fringe Benefits or ERE
- Operations
- Supplies
- Participants
- Travel
- Stipends
- Outside and Professional Services
- Indirect Cost
Restrictions generally apply to these categories and may not
allow deviation from the budget except in a prescribed
percentage. Example, if you are budgeted $10,000.00 for supplies
and the budget restriction states, "No deviation above 5% of
a budget category, not to exceed total award without
authorization in writing by Grantor", and you need to spend
more for supplies than budgeted, then you can only spend a total
of $10,500.00 without requesting a formal change or modification
to the budget, (10,000.00 * .05 = 500.00 + 10,000.00 =
10,500.00). The $500.00 would need to be recovered from other
budget categories because you cannot spend more than the total
approved award.
Supplemental Pay
Supplemental Pay for
Personnel on Sponsored Projects
Purpose
To allow for additional compensation for
supplemental activity performed for a sponsored project.
Sources
United States Office of Management and
Budget. OMB Circular A-21 (revised 8/8/00), Cost Principles for
Educational Institutions.
Human Resources Department.
Applicability
Faculty, administrative staff, and exempt
classified staff.
Policy
Sponsor regulations as implemented by
university policy generally prohibit routine payment of supplemental pay for
full-time employees. Provision for supplemental pay must be authorized in the
sponsor's award document and be authorized by the required university officials.
Prior written approval must be obtained from the sponsor for supplemental pay
charged to federal or sub-federal funds when provision for supplemental pay was
not approved in the proposal or award document.
Faculty Supplemental Pay
Chairs and deans may approve supplemental
pay if:
1) The supplemental work does not conflict
with the normal total responsibilities to the university for teaching, research,
public service, and committee and administrative duties.
2) The supplemental work is to be performed
for a department other than the employee's assigned department, or is a separate
or remote function.
3) Prior written approval of the employee's
chair/director and dean has been obtained.
4) The proposal and/or the award document
include specific provisions for supplemental pay, or prior written approval has
been obtained from the sponsor.
5) The rate of pay is consistent with the
employee's base salary from other university funds
and
6) The employee has not exceeded the hour or
percent of pay limitations permitted for that type of appointment.
Exempt Employees Supplemental Pay
(see NAU Human Resource Manual 2.03)
* Exempt employees are not eligible for
overtime compensation for extra hours worked. Generally, this definition
includes executive, administrative and professional employees.
* Exempt employees are not eligible to
receive overtime payment or compensatory time off. There are instances,
however, when flexible work hours may be permitted at the department head's
discretion to accommodate such things as peak work periods, for example, in the
case of an exempt employee who worked an excessive number of hours in a pay
period or who routinely works more than 40 hours in a workweek.
Procedure
To initiate supplemental pay for faculty or
staff from a sponsored project agency/orgn, the project director must complete a
supplemental compensation request prior to making final arrangements to begin
work.
Instructions are as follows:
1. Supplemental Compensation Requests MUST
be approved PRIOR to making final arrangements to begin work. When
approvals are completed, copies of the form will be returned to the
dean/director, area/orgn manager and the employee.
2. This form should ONLY be submitted for
supplemental compensation of FULL-TIME employees during periods of regular
employment (e.g., full-time faculty during the academic year only.) All
other requests (e.g., summer employment for faculty) should be submitted on a
Personnel Action Request form.
3. Compensation Rate shall be determined
according to ABOR policy, with the concurrence of the appropriate vice
president. Concurrence of Human Resources is also required for classified
staff rate.
4. After obtaining required signatures,
forward to the Budget Office, Box 4118, for processing.
Overtime Pay for Non-exempt
Classified Staff on Sponsored Projects
Purpose
To provide for overtime compensation for
more than 40 hours worked in a work week by a non-exempt classified staff member.
Source
Human Resources Department
Applicability
Non-exempt classified staff
Policy
Staff assigned to a sponsored project are
eligible for overtime compensation in accordance with the university's policies
and procedures established by the Human Resources Department.
Sponsored project personnel often have split
appointments between two or more agency/orgs. If the overtime work can be
directly identified with a specific appointment and agency/orgn, the overtime
compensation is charged to that agency/orgn. If the overtime work is
related to the employee's general duties and the employee is paid from multiple
agency/orgns, the overtime charges must be allocated proportionately.
Procedure for Non-exempt Employees
(see
NAU Human Resource Manual 2.03)
* Non-exempt employees must receive overtime
compensation or compensatory time off for extra hours worked. These
include employees not determined to be exempt.
* Overtime work shall be approved in advance
by the responsible supervisor. The appropriate supervisor is responsible for
scheduling overtime. Employees shall not work overtime unless specifically
authorized to do so by their supervisors.
* When a non-exempt employee works multiple
non-exempt positions, the number of hours worked in each position are cumulative
in determining eligibility for overtime.
* Non-exempt employees cannot waive overtime
requirements. All overtime hours worked must be recorded on a time sheet.
If an employee attempts to work extra hours without supervisor approval the
employee may be subject to disciplinary action. Conversely, if supervisory
personnel direct employees to work overtime without recording it, notice must be
given to the Human Resources Department so appropriate action can be taken.
Office of Grant and Contract Services
Responsible for:
- The dissemination of funding information.
- The submission of proposals.
- The negotiation of external agreements.
- The authorization of external agreements.
- The authorization to the departments to proceed with a
first funded grant or contract.
- Approving any budget changes and changes in directors on
existing projects.
- Provide information to the college/department on updating
the policy and procedures on non-financial information
such as 1) patent policy, 2) copyright policy, 3) use of
humans in research, and 4) technical report requirements
of the agencies.
Responsible for:
- Post-award activities for accounting and administration
of all grants, contracts and programs of funds restricted
by outside agencies.
- Institutional management on grants and contracts
beginning immediately after the award.
- Approve requisitions and reimbursements over $10,000 and payroll
activity.
- Plan, develop and maintain an effective accounting
system.
- Maintain the official Sponsored Projects Services'
account file and corresponding audit records.
- Monitor budgets and all accounting records.
- Preparation of all financial reports and invoices to the
sponsor. Review and sign all financial reports to outside
agencies.
- Counsel and advise principal investigators, directors and
account representatives in all financial affairs, agency
rules, regulations and policies involving grants and
contracts.
- Serve as liaison between the University administration
and faculty in administrative requirements of the
agreement.
- Serve as the sponsors' official University contact for
all post-award activity.
- Review and endorse any requests made of the sponsor
relating to any financial affairs.
- Coordinate the account close out including all financial
reports.
Responsible for:
- Execution of the technical aspects of the project;
including completing and submitting the technical,
property, invention, patent and copyright reports if
required.
- Adhere to University requirements for animal care, human
subjects and hazardous materials safety and security.
- Ensure all costs are reasonable, allowable and allocable per OMB
circular A-21
- Staff the project complying with University requirements
on hiring.
- Complete and return the "Effort Distribution"
reports to Sponsored Projects Services.
- Process purchase requisitions, Personnel Action Request
(PAR forms), and budget changes/transfers.
- Review the monthly accounting statements. Make sure all
manual records tie to the University official accounting
statements.
- Request extensions, if needed, in writing to the sponsor
at least sixty (60) days prior to the official end date.
Coordinate with the Office of Grants and Contracts.
- Request budget modifications in writing to the sponsor in
coordination with the Office of Grants and Contracts
Services for agencies who require them, before the
deviation occurs.
Each area that has grant/contract accounts and have
individuals being paid from those accounts will receive effort
distribution reports.
This system should, within reason, reflect the workload of
employees; accounting for 100% of the work for which each
individual is compensated.
Whenever it is apparent that a change in workload will occur
or has occurred, the change must be documented over the signature
of a responsible official and if significant, the change should
be entered into the system.
The report should reasonably reflect the percentage of
activity applicable to each sponsored agreement. To confirm that
the distribution of activity represents a reasonable estimate of
the work performed, each report must be signed by the employee
and by a responsible official having first-hand knowledge of the
work performed.
These effort distribution reports are used for audit purposes
to determine that each account is charged its correct amount and
are required by the federal government.
It is important that these reports are signed and returned to
the Office of Sponsored Projects Services, Box 4070.
For more information about this subject visit our Effort Distribution Reports page.
The Office of Management and Budget (OMB), working cooperatively
with federal agencies and non-federal parties, establishes
government-wide grants management policies and guidelines through
circulars and common rules. These policies are adopted by each
grantmaking agency and inserted into their federal regulations. The
two circulars most pertinent to our financial accountability
concerns are A-110 and A-21.
-
OMB Circular 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-21. This circular establishes principles for
determining costs applicable to grants, contracts, and other
agreements with educational institutions
Arizona Revised Statutes
As a state institution, NAU is required to comply with all
Arizona revised statutes. All grants, contracts and other legal
commitments entered into by the university must be in compliance
with these statutes.
Arizona Board of Regents
Because NAU is under the governance of the Arizona Board of
Regents (ABOR), it must also comply with ABOR regulations in grant
and contract administration as found in their
policy manual.
Treatment of Paid Absences
Vacation, holiday, sick leave pay and other paid absences are
included in salaries and wages and are charged to Federal
Projects as part of the normal charges for salaries and wages.
Separate charges for the cost of these absences are not made.
Treatment of Other Fringe Benefits
Our organization charges the actual cost of each fringe
benefit direct to Federal projects. However, it uses a fringe
benefit rate which is applied to salaries and wages in budgeting
fringe benefit cost under project proprosals. The following
fringe benefits are treated as direct costs: FICA, health
insurance, pension plan, unemployment insurance, and workers
compensation.
At times it is necessary to transfer expense from one account
to another. Care needs to be exercised when making the
determination that a transfer is a legitimate expense to the
account to which it is being transferred. If an account incurred
an expense in error then the expense should be transferred to the
correct account.
All transfers of expense, IX documents, should have supporting
documentation attached and departments should retain a screen
print of those documents processed.
Many granting agencies require that they give specific written
prior approval before financial budget changes are made. Contact
the Sponsored Projects Services office or the Office of Grant and
Contract Services for the specific requirements of your sponsor.
Written approval required by the University to the sponsoring
agency include the following:
- Change in scope or objective of the project
- Absence or change in Principal Investigator or key
personnel
- Change in grantee organization
- Subcontracting
- Any changes specifically prohibited by the terms and
conditions of the award.
All written requests to sponsors, when necessary, will be
initiated and justified by the Principal Investigator. The
Principal Investigator signs and forwards the request to the
Office of Grant and Contract Services (OCGS) after reviewing it.
If OCGS endorses the request it will be forwarded to the
sponsoring agency. Please note that the changes to the project
will not be made until written approval is received by the OGCS
from the sponsor. Prior approval requirements vary depending on
the agency. Please note that some agencies (such as PHS) grant
the Uiniversity expanded authority to approve some of the above
changes without obtaining prior approval from the sponsoring
agency. Also, National Science Foundation allows the Office of
Grant and Contract Services, as our Organization Prior Approval
Representative, authority to approve some of the above changes.
If any further information on prior apprival is needed, contact
the Office of Grant and
Contract Services.
Revenue is what you gain by performing a service or providing
goods.
Remember:
- Cash is Cash
- Cash is not Revenue
- Revenue is Revenue
In Advantage revenue is recognized on an accrual basis, not a cash
basis. This means revenue is recognized when the earnings process
is virtually complete.
A majority of grant and contract accounts are cost
reimbursable. As explained earlier, the University is entitled to
receive payment when expense has been incurred. Therefore the
earnings process is virtually complete and revenue is recognized
even though the cash has not been received.
Due to this feature, expense and revenue will be equal at the
beginning of each day after the nightly cycle and on the monthly
reports.
Some accounts that are not Federal or Federal Pass-Through
funds are programmed in Advantage where revenue is recognized on a
cash basis. Funds are deposited directly to revenue.
A number of grant and contract accounts become continuation
projects. Often when an account is awarded and authorized it has
an option to receive additional years of funding beyond what was
initially awarded. In coordination with GCS and the sponsoring
agency, the P.I. can request the additional awards.
In a significant number of instances the original project
cannot be completed by the approved end date. It is extremely
important that if a project needs additional time to be
completed, a "no- cost extension" should be requested
of the funding agency. This should be done in writing no less
than sixty (60) days prior to the official end date. This should
also be coordinated with GCS. Some agencies require 120 days,
therefore review your guidelines for no-cost extensions.
No account should run over budget. If it appears that
additional funds will be required to complete the project, then
additional negotiation will need to take place between NAU and
the funding agency. Again, GCS will help you do the negotiation.
The majority of agencies will not provide additional funds unless
there has been a significant change in the scope of work to be
provided. If there is a change in the scope, then budget
considerations should be addressed at that time. This is the
exception not the rule and those using grant and contract funds
should not spend the funds awarded with the idea that they can
request additional funds later. If an agency is open to awarding
additional funds there will generally be a statement indicating
so in the original agreement.
All of these situations should be addressed prior to the
occurrence, don't wait until the last minute.
Depending upon the situation, the account will either be
extended or a new account may be set up.
It is important for P.I.s and their support staff to be aware
of what the restrictions are and what stop or end dates need to
be honored.
These agreements are binding and need to be treated as any
other contract you may enter into. Any changes should be in
writing and any response from a funding agency should be in
writing. Verbal agreements are just as binding, but are far more
difficult to prove. Get it in writing.
Any changes to any externally restricted funds should be
communicated to SPS. Once a change is authorized SPS updates the Advantage system.
Indirect cost represents costs associated with the
administration of a project that cannot be identified to a
particular account.
Examples of Direct Costs are:
- Salary or Wage of those working on the project
-
- Director or P.I.
- Grad Assistants
- Secretary
- Undergrads
- Student Workers
- Associated Fringe Benefits for above
- Supplies
- Postage
- Printing
- Rentals
- Consultants
- Travel
- Participants
- Equipment
- etc.
Indirect costs are charged to grant projects to cover
administrative expenses that cannot be charged directly to the
account. For example, the staff of SPS works solely on grant
accounts, but no one from SPS receives their pay directly from a
grant account.
In order to track the time SPS spends on each account and
apportion an amount of its salary to each account based on the
time spent on each project would cost more than would or could be
gained.
Payroll, Accounts Payable, Purchasing, Custodial, Utilities,
and Maintenance are all examples of work performed in regard to
grant accounts, but are not paid from Sponsored accounts
directly.
These costs are indirect costs and accounts are charged an
indirect cost rate to help the University recapture at least a
portion of the costs associated with dealing with outside
funding.
For more information about this subject visit our Indirect Costs page.
SPS places the third level of approval on all PD and RX
documents that are on a grant or contract accounts that are over $10,000.00
Chuck Bernhardt is the individual in the Sponsored Projects
Services Office who is delegated responsibility by the University
for approving these documents. In the event that Chuck is
unavailable, (ie. vacation or sick leave), Dani and Kevin are
authorized to give approval.
SPS does not approve IX, IV, RC, or TE documents. SPS does,
however, review IX and IV documents on daily reports and TE's are
viewed on line prior to the Travel Department placing the fifth
level of approval on the document.
NAU policy for capitalization of assets is, effective July 1,
1996; items costing $1,000.00 or more in value and have a useful
life of more than one year should be capitalized. With the
exception of data processing equipment and computer software.
Software, however, that is purchased as a part of a computer
package is a part of the computer and is capitalized. All
computers, printers and peripherals (capital or not) will contiue
to be both tagged and inventoried to facilitate tracking for
Computer Services. This is regardless of the dollar amount.
Assets are capitalized at cost including tax, freight and all
other costs required to bring the asset to its full useful state
to the University. Maintenance and repair costs are not
capitalized.
For equipment costing at least $2,500.00 the University
requires a statement signed by the project manager to accompany
the requisition stating that the item being purchased or a
similar substitute is not available for use in the department.
Equipment costing in excess of $10,000.00 must undergo a
screening with University property records to determine that
similar equipment does not exist in other units which may be
available for shared use. There must be a statement on file,
signed by the University Property Administration Office verifying
the screening process and the outcome.
Equipment owned by Federal agencies may not be available for
shared usage without the written consent of the Federal agencies
contracting officer.
Title of Fixed Assets
In order to determine where the title of property, purchased
with external funds, will reside one must examine the funding
agencies guidelines.
The Federal government uses $5,000.00 or more per unit cost to
determine whether title resides with the Federal government or
the University for property purchased with Federal funding. For
items costing under $5,000.00 title resides with the University.
For items costing $5,000.00 or more ownership is vested with the
Federal government. We must pay particular attention to items in
which ownership is vested with the Federal government in
determining use of those items. The University may continue to
use Federal government property on the same project or program
for which it was purchased even though Federal funding has ended.
If the property is no longer needed for the particular program
for which it was purchased the property may be used for other
programs or projects which receive Federal funding from the
original funding agency. If no programs under that particular
funding require the use of the property or equipment then that
equipment may be used on other programs which receive funding
from other Federal agencies. In the event there are no other
Federal programs for which the property may be used then the
University must submit a request for disposition instructions to
the original Federal funding agency. The Federal government is
required to issue disposition instructions within 120 calendar
days from the date of the request. If disposition instructions
are not received within the appropriate time frame then the
University is required to sell the property. The proceeds of the
property shall be disbursed using the Federal calculation found
in Circular A-110. If disposition instructions are received then
the University follows the order of disposition in the notice.
Other non-federal agencies may have different guidelines and
should be determined on an individual case basis.
For property purchased on fixed price contracts title
generally resides with the University. It is important to always
review the rules and regulations applicable to each individual
project.
All sponsored projects are subject to audit by the sponsoring
agency. All audits are the responsibility of the Sponsored
Projects Services Office. If a department/Principal Investigator
is contacted directly by the Auditor, the Auditor needs to be
referred to SPS. To reduce cost and time to sponsoring agencies
and the university the Federal government has adopted a policy of
appointing one Federal agency as the "cognizant audit
agency." The Department of Health and Human Services is the
cognizant audit agency for Northern Arizona University.
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