Grants & Contracts (cont'd)

Purpose: The policy is set forth to minimize the risk of unauthorized use of funds on federal, federal flow-through, foundation and other private grants and contract projects, and to ensure that cost on these projects are within the scope and guidelines of the sponsoring agencies. Therefore, entries in the PeopleSoft General Ledger (PSGL) must be monitored monthly, cost sharing commitments must be met, and close out and reporting must be timely and accurately done.
References: MAPP 05.04.02, SAM 03.G.03
Procedures:
PT. I: Pre Award PT. XI: Contracts/Consulting Agreements
PT. II: Types of Awards and Sponsors PT. XII: Inventory/Equipment on the Grant
PT. III: Interim Funding PT. XIII: Closing Projects in the Department
PT. IV: Allowable vs. Non Allowable Costs (A21) PT. XIV: Record Retention
PT. V: Maintaining a List of Project Cost Centers PT. XV: Audits
PT. VI: Reconciling Projects in the Departments PT. XVI: Accessing Transmittal Forms Submitted Through NSM
PT. VII: Cost Transfers PT. XVII: RD2K Instructions for Loading Technical Reports
PT. VIII: Cost Sharing/Matching Funds PT. XVIII: Federal Grant Newsletters and Guide to Managing Federal Grants
PT. IX: Travel PT. XIX: Allowable/Unallowable Costs on Projects
PT. X: Sub-Recipients    
Review and Responsibility:
  • Responsible Party: Director, NSM Business Operations
  • Review: Every two years, on or before August 31
Approval:
  • Director, NSM Business Operations - Fred McGhee
  • Dean, NSM - John Bear
  • Date of Dean's Approval: 09/01/2008

XIII. Closing Projects in the Department

A formal closing out of projects, at the departmental level, when they expire will help to reduce the many expired project cost centers which have negative or positive balances. A plan of action to zero out these cost centers is as follows: Within 90 days after the end of the funding period, determine if the project will continue with a no-cost extension or if additional funding from the sponsor will be added to the project. Be sure that the additional funds will be added to the same cost center. If the project has ended, send an email to the faculty member(s), the purchaser, and the payroll staff informing them of the pending closing and advising them of the balances and the need to payoff all outstanding commitments before the 90 day period. Accordingly, invoices from vendors and contractors, payments to consultants and all wages must be processed within the 90 days. Although most projects have a 30-90 accounting date period after the end date to reconcile and pay all outstanding commitments, commitments not dated within the project granting period will not be honored. Prior to close out the DBA should review the agency’s regulations and the program specific rules to assure that all reporting requirements will be met. The PI is responsible for the technical report and the DBA is responsible for communicating accurate figures to OCG for the final financial report submitted to the agency. OCG will email the DBA and the PI a copy of the final billing before submitting it to the agency. If the grant or contract has ended with a positive balance and it is a cost reimbursable project, the funds will be de-obligated on PS and the overage stays with the sponsor at the time of the final reporting. If the award is a Fixed Price award, and there is a positive balance of less than 23% of the original award, the DBA can request that the balance be transferred to a residual funds cost center. However, if the positive balance is over 23%, the PI must prepare a technical reason for the excess to be transferred to a residual cost center or ask the agency for an extension. If the grant or contract has ended with a negative balance on any type of project, prepare a reallocation/journal to move the excess expenditures to a non-grant cost center. Appendix V contains a project close out check list to be used by department reconcilers.

XIV. Record Retention

Universities are legally required to retain all financial and other records pertinent to the project for a minimum of three years after submission of all financial reports and to have these records available for any subsequent audits or review by the sponsors. Some sponsors may specify a longer retention period, in which case the records must be kept for the period requested.

XV. Audits

Grants, contracts and agreement in the departments are subject to audits. OCG is responsible for coordination of these audits. OCG may request information from the departments or the PI. The PI and the DBA is responsible for providing the necessary information to OCG. Therefore, the PI and the DBA is responsible for retaining complete grant/contracts/agreement files. The types of audits are:

  • Grant/Contract Audit from the sponsoring agency
  • Contract close out Audit from the sponsoring agency or our cognizant audit agency (DHS)
  • System Audit that comes from our internal auditors
  • A-133 compliance audit that comes from an independent auditor hired by the University of Houston.
  • Investigations from whistleblowers.
  • Site visits from an agency like NSF or EPA that reviews awards. This is not an audit but the same level of documentation and review is needed.

Continue to PT. XVIII: Federal Grant Newsletters and Guide to Managing Federal Grants...