Responsibility for Maintenance: Academic Affairs; Financial Services
Date of most recent changes: May 18, 2026
I. Policy Statement
As a recipient of federal awards and other sponsored projects, Onondaga Community College is required to ensure that internal controls are maintained in accordance with 2 CFR 200.303 to provide reasonable assurance that sponsored project funds are used solely for authorized purposes, consistent with applicable regulations, award-specific terms and conditions, and support achievement of objectives related to effectiveness and efficiency of operations and the reliability of grant reporting for internal and external use. This responsibility includes:
Project-based (“accumulated”) accounting records are maintained with appropriate supporting documentation;
Principal Investigators (PIs) and Project Directors (PDs) actively monitor and authorize uses of sponsored funds, including the work of subrecipients and contractors, and document these uses in relation to project objectives for review by the funding agency, ensure compliance with award-specific requirements, and ensure implementation of College procedures related to financial management, human resources, procurement, contract accounting, information technology, and grants administration; authorize and direct financial transactions of the sponsored activity; monitor and report on the financial status of each sponsored project in relation to the sponsored project's stated plan or objectives; and ensure timely preparation of required documentation;
Effort reporting is consistently, accurately, and timely documented by the individual working on a grant-funded project and verified by the PI or the PD;
Potential conflicts of interest are disclosed and resolved or mitigated; and
Sensitive data associated with sponsored projects, including personally identifiable information (PII) is safeguarded through reasonable administrative, technical, and physical controls.
II. Reason for Policy
This Policy complies with federal regulations governing the uniform administrative management, cost principles, and audit requirements for federal awards, including OMB Guidance for Federal Financial Assistance (2 CFR Part 200). To achieve consistency in post-award grants management, these principles are applied to all federal and state grants and cooperative agreements, unless the sponsor requirements for a specific award are more restrictive, in which case the more restrictive requirements apply.
III. Applicability of the Policy
College faculty, staff, and all individuals and organizations funded through a grant award, including subrecipients, are subject to this policy.
IV. Related Documents
OCC Policy K5: Federal Project Incident Reporting
Onondaga Community College Inventory Control Procedures
Onondaga Community College Purchasing Procedures Manual
Onondaga Community College Purchase Requisition Forms
Sponsored Project Conflict of Interest Disclosure Form
V. Contacts
Subject | Office Name | Title or Position | Telephone Number | Email/URL |
Administration and Compliance | Academic Affairs |
| (315) 498-2594 | |
Administration and Compliance | Financial Services | Senior Vice President for Administration, Enrollment & Finance | (315) 498-2220 |
VI. Definitions
A direct cost is reasonable, allocable, and allowable and can be identified specifically with a particular sponsored project.
Modified Total Direct Costs (MTDC) means all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and the first $50,000 of each subaward, excluding equipment, capital expenditures, participant support costs, tuition remission, rental costs, scholarships and fellowships.
An indirect cost (Facilities and Administrative cost) is incurred by the institution for its general facilities and administrative operations and cannot be identified specifically with a particular sponsored project.
A cost is reasonable if the nature of the goods or services obtained on behalf of the sponsored project and the amount spent for those goods or services reflect the action that a prudent person would have taken under similar circumstances to accomplish the project’s objectives. (see 2 CFR 200.404)
A cost is allocable if it is incurred solely to benefit the sponsored project or to benefit both the sponsored project and the work of the institution. If the cost benefits solely the sponsored project, it may be assigned fully to the project. If the cost benefits both the sponsored project and other objectives of the institution, then the cost generally may be assigned to the sponsored project in proportion to the benefit to be gained by the project. (see 2 CFR 200.405)
A cost is allowable if it is necessary, reasonable, allocable; conforms to any limitations or exclusions set forth in the Federal Cost Principles or in the Federal Award as to types and amount of cost items; is consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-federal entity and accorded consistent treatment as a direct or indirect cost; consistent with generally accepted accounting principles appropriate to the circumstances; not prohibited by regulations or the terms of a specific sponsored agreement; and adequately documented. (see 2 CFR 200.403)
Unallowable costs may not be included as a direct cost of a sponsored project nor calculated as part of indirect costs, unless specifically provided for in the sponsored award agreement or negotiated directly and confirmed in writing from the awarding agency. Unless explicitly authorized by the award agreement, unallowable costs include, but are not limited to:
Alumni activities and alumni relations
Commencement and convocation ceremonies
Creation or contribution to financial reserves
Entertainment: amusement, diversion, social activities and associated costs, such as tickets to events, meals, alcoholic beverages, lodging, rentals, transportation, or gratuities
Fund raising activities or materials
Personal expenses, including memberships in social, dining or country clubs, and good or services obtained for personal use
Investment management, bad debt losses, internal interest expense, fines and penalties
Lobbying activities
Public relations unrelated to the performance of the sponsored project
Student activities, such as student clubs or intramurals
Compensation of personnel in excess of federal salary caps or inconsistent with institutional standards or practices.
A conflict of interest exists when a PI’s or PD’s financial interests or those of their immediate family members may be affected by the externally funded activity.
VII. Procedures
1. Upon receipt of an award, the Principal Investigators (PI), Project Directors, and Department or Division Heads responsible for the grant award will review the award agreement terms and conditions, applicable guidelines, agency implementing, regulations, and this policy.
2. Financial Services will set up a non-operating grant account code and load the approved grant budget in the College's financial software.
3. At the outset of a new sponsored project or upon a succession in PI or PD, the PI and PD will participate in orientation with Financial Services and Grants Administration to review applicable procedures, reporting obligations, forms, and timelines. PDs managing federal grants must complete training on federal grant management and compliance at least annually.
4. The PI and PD will complete a Conflict of Interest Disclosure Form and submit to Grants Administration within thirty (30) days of commencement of a new award year or upon appointment to a project, and each year thereafter for multi-year, sponsored projects. In addition, the PI and PD will notify Grants Administration promptly upon the occurrence of any changes that affect an earlier submitted disclosure. If a conflict of interest is disclosed, the Senior Vice President & Chief Financial Officer will be advised and will determine, in collaboration with the involved parties, how the conflict of interest will be resolved or mitigated. If resolution cannot be reached collaboratively, the President will determine the appropriate resolution.
5. All employees who have committed a percentage of their time to support a federally-sponsored project must complete a time and effort report to certify the work performed based on an after-the-fact determination of actual effort. This requirement applies to employees whose salary is paid through the grant, as well as employees paid through the College who are contributing time as a cost-share or in-kind match. In addition, the PI and PD will assure that personnel costs charged to a project are consistent with the proportionate benefit received by the project.
Employees who dedicate 100 percent of their time to one federally-sponsored project must complete a form certifying that 100 percent of their effort for the designated period was dedicated to the project.
Employees who contribute a portion of their time (less than 100 percent) must complete a time and effort form documenting the allocation of their time across projects, based on an after-the-fact determination of the actual activities (i.e., time and effort cannot be estimated in advance). For example, the distribution of the time might be determined based on notes from personal calendars and/or reasonable estimates of time spent on various activities.
6. The PI and PD will ensure that time and effort reports are completed in accordance with the schedule established at the start of the grant project and/or at the time an employee is appointed to a sponsored project, if appointed after the start of the grant project. Effort reports will be prepared and certified by the employee whose time is fully or partially allocated to the grant, and reports will be reviewed and approved by the PI, the PD, or a designee, who has been identified to Grants Administration, and who has direct knowledge of the work performed by the staff member whose time and effort is being reported.
7. The PI and PD will oversee the finances of his or her specific sponsored project(s); monitor and authorize expenditures in accordance with the approved proposal budget, and award terms; confirm that all authorized costs are allowable, reasonable, and allocable under the terms of the grant agreement and approved budget; and, ensure that appropriate documentation is collected and retained for each transaction. Compensation procedures and rates for employees assigned to sponsored projects are consistently applied to sponsored and non-sponsored activities; however, additional restrictions and documentation may be required by the sponsoring agency and applicable regulations and guidelines. The PI/PD must ensure that supporting documentation for expenses is submitted to Financial Services. Financial Services will retain official financial records in accordance with the retention period required for the award and College record retention requirements.
8. The PI and PD will ensure consistent implementation of College procedures related to financial management, human resources, procurement, contract accounting, information technology, and grants administration. The PI and PD will consult as necessary with the administrative offices that coordinate these functions.
9. The PI and PD will supervise and monitor the work of subrecipients in accordance with Policy K7 and applicable federal requirement, including risk-based monitoring and documentation of performance.
10. The PI/PD will monitor spending and progress toward program deliverables. Monitoring should occur at least monthly for the life of the project. Financial monitoring must include an analysis of spending in relation to progress toward project objectives. Any material variances must be documented and communicated to the Division head, Financial Services, and Grants Administration for corrective action in consultation with relevant stakeholders and the funding agency when necessary.
11. Some modifications to an approved project and/or budget require prior, written approval from the funding agency. PIs and PDs are responsible for identifying if modifications are needed and for working in collaboration with Grants Administration and Financial Services to request permission from the funding agency to modify the project or project budget.
12. Financial Services will determine the applicable indirect costs of a sponsored project in accordance with the federally-approved indirect cost rate and guidelines of the grant program. In addition, if cost-sharing is required for a sponsored project, Financial Services will authorize the funds to be matched and will work with the PI and PD to collect and maintain required documentation demonstrating the applicable cost-sharing requirement has been met.
13. Financial Services will collaborate with PIs and PDs to maintain an inventory of all equipment purchased with federal funds with a useful life of one year or greater and a per unit purchase price of $5,000 or greater for items purchased prior to September 1, 2025 and a per unit cost of $10,000 or greater for items purchased on or after September 1, 2025, supported by awards issued on or after October 1, 2024.
Such equipment must be used for the project or program for which it was purchased for as long as that project or program exists. If the sponsored project or program no longer exists, the equipment must be used for another federal project of the same funding agency or, if none exists, a project of a different federal agency. If no other federal project exists, then Grants Administration and Financial Services will consult with the applicable federal agency on the proper disposition of the equipment.
Such equipment must be maintained so as to minimize potential for loss or damage, and accurate inventory records must be maintained to identify the equipment and its specific location.
A physical inventory will be conducted annually by the Department that purchased the equipment. Management Services also will conduct periodic physical inventories and the results reconciled with equipment records.
14. All PIs and PDs must comply with external and internal reporting requirements and deadlines established by the sponsor For federal awards, final financial, performance, and other required reports must be submitted no later than 120 calendar days after the end of the period of performance, unless the sponsor specifies an earlier deadline. Grants Administration reviews and submits final grant reports to external funding agencies, unless alternative procedures are established to comply with award-specific terms and conditions and the sponsor’s reporting system and requirements. Financial Services reviews and approves all financial reports prior to submission. In addition, final reports are saved the Grants Sharepoint folder and key outcomes are included in grant summary reports.
15. Records Retention: The College shall retain financial records, supporting documents, data, and all other records pertinent to federally‑sponsored and other sponsored projects for a minimum of three (3) years, as required by 2 CFR §200.334, unless a longer retention period is required by the awarding agency, pass‑through entity, sponsor‑specific regulations, or state law, or the type of documentation requires a longer retention period. For Federal awards, the retention period generally begins on the date of submission of the final expenditure report or, for awards that are renewed annually, from the date of submission of the annual financial report, as applicable. In cases where the award agreement, state statute, sponsor policy, or pass-through entity requires a period of retention longer than three years, the longest applicable retention period will be followed. Exceptions include:
(a) Litigation, Claims, or Audits: If any litigation, claim, audit, or other compliance action is initiated before the end of the retention period, records must be retained until all issues are fully resolved and final action has been taken.
(b) Real Property and Equipment Records: Records related to the acquisition, use, management, and disposition of real property and equipment acquired with sponsored funds must be retained for three years after final disposition, or longer if required by the sponsor.
(c) Records Supporting Federal Indirect Cost Rate Proposals must be retained for three years from the date of submission if the proposal is not negotiated; or for three years from the end of the fiscal year covered by the proposal if the rate is negotiated.
16. Disposal of Records: At the conclusion of the applicable records‑retention period, records shall be disposed of in a manner that protects confidential, proprietary, or personally identifiable information (PII) and complies with College policies and applicable requirements. Records related to open audits, investigations, litigation, or claims may not be destroyed without written authorization from the Senior Vice President and Chief Financial Officer or College President.
Approved by the OCC Board of Trustees June 20, 2017
Updated and approved by the President June 15, 2020
Updated and approved by the President June 26, 2023
Updated and approved by the President June 9, 2025
Updated and approved by the President May 18, 2026