K4: Post-Award Financial Management of Sponsored Projects

Responsibility for Maintenance: Academic Affairs; Financial Services

Date of most recent changes: June 26, 2023

I. Policy Statement

As a recipient of federal grants and other sponsored projects, Onondaga Community College is required to ensure that internal controls are in place to provide reasonable assurance that grants funds are used solely for authorized purposes, consistent with applicable regulations, and support of achievement of objectives related to effectiveness and efficiency of operations and reliability of grant reporting for internal and external use. This responsibility includes;

  • Project-based (“accumulated”) accounting records are maintained with appropriate back up documentation;
  • Principal Investigators (PIs) and Project Directors (PDs) actively monitor and authorize uses of sponsored funds, including the work of sub-awardees, and document these uses in relation to project objectives for review by the funding agency 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. 

II. Reason for Policy

This Policy complies with federal regulations governing the uniform administrative management, cost principles, and audit requirements for federal awards. To achieve consistency in post-award grants management, these principles are applied to all federal and state grants and cooperative agreements.

III. Applicability of the Policy

College faculty, staff, and all individuals and organizations funded through a grant award, including sub-awardees, are subject to this policy. 

IV. Related Documents

V. Contacts

Subject  Office Name  Title or Position  Telephone Number  Email/URL 
Administration and Compliance Academic Affairs   (315) 498-2594 provost@sunyocc.edu
Administration and Compliance Financial Services Senior Vice President and Chief Financial Officer (315) 498-2668 m.r.manning@sunyocc.edu

 

VI. Definitions

  • A direct cost is reasonable, allocable, and allowable and can be identified specifically with a particular sponsored project.
  • An indirect 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. 
  • 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.  Unallowable costs generally include:
  1. Alumni activities and alumni relations
  2. Commencement and convocation ceremonies
  3. Creation or contribution to financial reserves
  4. Entertainment:  amusement, diversion, social activities and associated costs, such as tickets to events, meals, alcoholic beverages, lodging, rentals, transportation, or gratuities
  5. Fund raising activities or materials
  6. Personal expenses, including memberships in social, dining or country clubs, and good or services obtained for personal use
  7. Investment management, bad debt losses, internal interest expense, fines and penalties
  8. Lobbying activities
  9. Public relations unrelated to the performance of the sponsored project
  10. Student activities, such as student clubs or intramurals
  11. Compensation of personnel in excess of federal salary caps or inconsistent with institutional standards or practices.
  12. 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 and applicable guidelines and regulations.

2. Financial Services will set up a non-operating grant account code and load the approved grant budget in Colleague.

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 will complete annual training on federal grant management and compliance.

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 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. 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 appropriate personnel are trained in time and effort reporting and ensure that time and effort is timely (at least quarterly) reviewed, authorized, and submitted to Financial Services 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 and budget on file with the funding agency; 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 maintained 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. Financial Services will serve as the official repository for expense documentation to ensure that documentation is maintained consistent with College policies and procedures and applicable regulations.

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 sub-awardees and subcontractors and will authorize payments to sub-awardees and subcontractors consistent with the work performed. Management Services and Grants Administration will work with PIs and PDs to establish agreements with any project partners that will receive grant funding and/or have committed to support a specific activity or deliverable associated with the grant project. 

10. The PI and PD will monitor and report on the financial status of each sponsored project in relation to the sponsored project’s stated plan or objectives.  Monitoring of spending and progress toward program deliverables should occur at least monthly for the life of the project. Federally sponsored projects require analysis of spending in relation to the attainment of project objectives and a plan for addressing any misalignment between proposed and actual spending and proposed and actual attainment of the objectives outlined in the original grant proposal.  The PI and PD will ensure timely preparation of required documentation and provide to Financial Services and Grants Administration for consultation, review, submission to funding agency, and records retention.

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 purchase price of $5000 or greater. 

  • 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 periodically conducted by Management Services and the department heads and the results reconciled with equipment records.

14. All PIs and PDs must comply with external and internal reporting requirements and deadlines, allowing sufficient time for internal review and approvals. Grants Administration reviews and submits final grant reports to external funding agencies, unless alternative procedures are established due to the unique nature of the grant award or reporting requirements. Financial Services reviews and approves all financial reports prior to submission. In addition, final reports are posted to the Grants Sharepoint folder and key outcomes are included in grant summary reports.

  

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