Date: January 6, 2012, Revised March 22, 2018
Purpose
This procedure outlines ODU Research Foundation (ODURF) procedures for sponsored programs awarded to Old Dominion University (ODU) and established as accounts under the University’s Ledger V.
Who Needs to Know This Procedure
Principal Investigators
Co-Principal Investigators
University Faculty
University and Research Foundation staff responsible for sponsored programs administration
ODU Policy
Grants and contracts that may be accepted in Ledger V will include those in which the agency requires, with accompanying documentation, that the university or other public entity be the awardee of record to accept and/or administer the award and other circumstances where ODURF is ineligible to receive the award by virtue of its corporate status. The vice president for research will make a determination whether or not the Ledger V account is subject to 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), in general, including standards for allowability of costs, cost transfer, cost sharing, fixed asset, and effort reporting, in particular. If the Ledger V account is a sponsored program subject to Uniform Guidance, the vice president for research will also determine whether to assign it to ODURF to administer. No project activity for such account may start without a formal proposal signed off by either ODU office of research or ODURF or both.
Federal Requirements
Educational institutions that receive Federal grants and contracts (including Federal flow through projects) must comply with Uniform Guidance, which sets forth the governing rules for determining the various costs that can be charged to grants and contracts, and for establishing whether those costs may be charged directly, or charged through the application of the institution’s Facilities and Administration (F&A) rate. ODU and ODURF apply these same cost principles to non-federal funding as well in order to be consistent. In some instances, program-specific requirements may define costs differently than is generally the case for federal sponsors.
The cost principles include Cost Accounting Standards (CAS) with which both ODU and ODURF are required to comply. The standards are listed in 2 CFR Part 200, 200.419 and require educational institutions with annual federal sponsored programs expenditures of $50 million or more to submit a disclosure statement (DS-2) to their cognizant agencies. ODU and ODURF submitted their joint DS-2 to the Office of Naval Research as required. ONR determined adequacy of our disclosure per FAR 30.202-7(a) on March 31, 2007 and the most recent determination of adequacy was received on January 7, 2011.
CAS seeks to (a) make the best use of available funds to achieve outcomes; (b) avoid problems of fraud, waste, and abuse of sponsor support; (c) prevent the charging of unallowable costs to awards; (d) standardize university costing practices; and (e) standardize requirements for recipients of federal funds. Non-compliance may result in sanctions, including fines and penalties, exclusion or suspension from participating in federal programs, and or criminal charges. The mandated federal standards are:
1. 48 CFR 9905.501: Consistency in Estimating, Accumulating and Reporting Costs
Principal Investigators and administrative support personnel must ensure compliance with this standard by maintaining consistency in the manner in which budgets are prepared during the proposal submission period, and how those funds are budgeted and expenses accounted for upon receipt and during the life of an award.
2. 48 CFR 9905.502: Consistency in Allocating Costs Incurred for the Same Purpose
The University must ensure compliance with this standard by ensuring that costs incurred for the same purposes, in like circumstances, must be given consistent treatment in the accounting system.
3. 48 CFR 9905.505: Accounting for Unallowable Costs
Principal Investigators and administrative support personnel must ensure compliance with this standard by insuring that those costs defined as “unallowable” are not directly charged to Federal projects, and when incurred in accordance with university policy, are charged to other funding sources and identified as “unallowable” so that those costs are excluded as well from the University’s F&A rate.
4. 48 CFR 9905.506: Cost Accounting Period
This standard requires that the University comply with a number of rules governing how costs are treated for the purpose of calculating and negotiating the University’s F&A and other institutional rates.
Applicability
This procedure applies to all sponsored programs, Federal (including Federal flow through funding) and non-Federal, awarded to ODU with postaward management delegated to ODURF.
Procedure
ODU Office of Finance
Within the ODU Office of Finance, organization codes are established to record accounting transactions for each grant by award year. Upon completion and approval of the “Request for Establishment of University Organization” form, the Project Directors and ODURF, if applicable, are notified of their respective budget number. A copy of the grant budget is submitted to the Budget Office for processing.
Principle Investigators (PI)/Budget Unit Directors are responsible for managing and monitoring each award function or activity supported by the award to ensure all applicable guidelines and regulations are met by reviewing financial data recorded in Banner and preparing reports timely. The PIs must work to ensure that they maintain high standards, achieve their stated goals and objectives, meet agreed upon deadlines, stay within budget, expend funds as required, comply with the granting entity’s terms and conditions, maintain appropriate records, meet financial and programmatic reporting requirements, and communicate results. The Grant Accountant is responsible for accounting, verifying that the expenditures/revenues relate to the specific objectives funded in the grant contract/agreement, provide guidance for budget changes and maintain effective control over and accountability for all funds, property and other assets.
ODURF
After all needed forms are completed, the PI obtains all required signatures (PI, Dean, VP of Academic Affairs, VP for Research) and delivers the materials to the ODURF grant and contract administrator (GCA).
GCA reviews forms for completeness and assures that the RF project number is written in the upper right-hand corner of the Request for Establishment of University Organizational Code. The GCA then delivers the following Ledger V paperwork to the ODU Office of Finance:
After the ODU Office of Finance receives the Ledger V paperwork, they assign an ODU Budget code number (five-character alpha/numeric code). This number is written on the ODURF project abstract and in the “Notes” section of the ODURF Project Setup sheet. The GCA then notifies the PI and the ODURF Accounts Receivable Technician of the ODU budget code.
Once the ODURF account is established, the project is administered by ODURF staff consistent with routine sponsored program practices and ODURF procedures, including travel guidelines and procurement processes, will apply. The GCA monitors expenditures and works with the PI on administrative matters, such as sponsor approvals or no cost time extensions.
Throughout the project and particularly at close-out, the GCA coordinates with the ODURF Accounts Receivable Technician to ensure that the ODURF’s final invoice is submitted to ODU early enough, at least two weeks in advance, to allow ODU to meet the sponsor’s final invoice due date.