Office of Research and Project Administration

SPONSORED PROGRAMS COMPLIANCE

13. Documenting Allocability

Administrative Responsibilities/Issues:

• Review terms and conditions of award and information contained in internal Notice of Award. Compare Notice of Award with award letter from sponsor.
• Review of funded proposal for personnel on project and type of allowable expenditures permitted by approved budget and sponsor.
• Change of personnel percent of effort distribution as appropriate for project. Personnel action forms should be signed by principal investigator and administrative staff member. Provide copy of clean turn-around form to personnel on project.
• Change account number to service departments and notify laboratory personnel on project of new account number and sponsor information, restrictions, etc.
• Purchases may be made by only those personnel listed on proposal sign-off as authorized to charge against account.

  • Modify sign-off as appropriate, or
  • PI write memo to file indicating persons allowed to charge against account.
  • Notify the Office of Research and Project Administration (ORPA) (photocopy of memo, e-mail, etc.)
• Purchases are made on project as are deemed appropriate for the scope of work of the project and/or as identified in approved budget.

  • More than one funded grant in the same laboratory suggests the sharing of general laboratory supplies, etc. among grants. Purchases should be charged appropriately to each grant, whenever vendor permits split distributions.
  • Where split distributions are not possible, multiple orders to separate account numbers is recommended.
• Rebudgeting of project budget is not based solely on dollar amount permitted by sponsor, but as related to the project scope (e.g., does the rebudgeted item change the scope of the project, regardless of whether it is within the rebudgeting guidelines?).
• Monthly review of ledgers by an administrative staff member and the principal investigator.
• Reconcile monthly ledger with departmental encumbrance accounting system.
• Monthly certification of ledger expenses by PI. Administrative staff member should identify any problem-areas to PI and note on the monthly ledger certification form. A sample monthly ledger certification form can be found at: http://www.rochester.edu/adminfinance/audit/ listed under PI Ledger Approval Sample Form.
• Obtain signed ledger certification sheet from PI. 100% compliance should be standard and is best practice.

Cost Transfers

• Requesting a contingent account number, if pre-award costs are permitted by sponsor, will help to avoid cost transfers or reallocations.
• Avoid cost transfers whenever possible. Some cost transfers for personnel costs are a result of a delay in award receipt. Follow cost-transfer signature guidelines (e.g., 30 days, PI; 60 days, PI/Chair, 90 days, PI/Chair/Dean's Office).
• Review of monthly ledgers may result in required cost-transfers as a result of erroneous account numbers, data entry errors, etc. Timely review of monthly ledgers will result in early identification of potential cost-transfers.
• AVOID cost-transfers at the end of a budget or project period, which is a signal to internal and sponsor auditors that the cost transfer was a result of trying to spend down money or correct deficits. Monitor monthly expenditures to plan on-target spending for the funded budget/project period.
• Cost transfers should be well justified and well documented. Save all back-up documentation and obtain signature of principal investigator on all related materials.

  	Sample Reallocation Memo

  • Cost transfers should meet the following three points:
    • Why original cost was inappropriate to account charged.
    • Why cost to be transferred is appropriate to account to be charged.
    • Explanation of reason for error on the account.