The cost principles of OMB A-21 state that expenses for administrative and clerical activities in academic departments and institutes should normally be treated as indirect costs and not as a direct charge to federally sponsored programs. Salaries of administrative and clerical staff, office supplies, postage, local telephone costs, and memberships are considered administrative expenses.
The Office of Management and Budget (OMB) has provided guidance on when the direct charging of these costs is allowable. Direct charging of these costs may be appropriate where the nature of a particular project requires an extensive amount of administrative or clerical support, i.e., a level that is significantly greater than the routine level provided by academic departments. The costs must also meet the general criteria for direct charging, i.e., the costs can be identified specifically with a particular sponsored project and the special circumstances requiring the direct charge have been approved by the awarding agency. See Exhibit C from OMB A-21 for OMB interpretation and examples of such circumstances and conditions.
The following guidelines, which have been developed to meet the OMB A-21 requirements and interpretation, became effective for charges to federally sponsored agreements beginning July 1, 1996.
Administrative and clerical salaries
-- Academic departments and institutes
The following criteria must be met to charge administrative or clerical salaries directly to federally sponsored projects:
- the approved proposal budget must list the administrative or clerical personnel by position and the budget justification/explanation should describe the special circumstances requiring the direct charging of these services, and
- the administrative or clerical personnel must be specifically identified with the project. This specific identification is reported by identifying the direct effort on the Time Allocation Report or other appropriate method used for effort reporting. Pooled allocation methods (any method which does not reflect the time spent by a given individual on a specific project) may not be used to direct charge for administrative or clerical services.
Administrative Supplies and Expenses
-- Academic departments and institutes
The following supplies and expenses are normally indirect costs: postage, local telephone costs, general office supplies, and memberships. These supplies and expenses should not be charged directly to federally sponsored programs, unless circumstances under the award justify such direct charges specifically for the technical purposes of the award and all of the following criteria are met:
- the supply or expense must be listed in the approved proposal budget (i.e., postage, local phone costs, etc.) and the budget justification/explanation should describe the special circumstances requiring the direct charging of these costs, and
- the supply or expense must be specifically identified with the project or activity. Note: purchase requisition or other supporting documentation is required to support the specific identification of the charge. Pooled allocation methods (any method which does not charge directly based on the actual use) may not be used.
The above criteria must be met to directly charge administrative and clerical expenses to federally sponsored awards. The attached flowchart summarizes these guidelines. Note: with specific agency approval, rebudgeting to charge administrative or clerical salaries is permitted; internal rebudgeting for this purpose is not permitted.
The above criteria must be met to directly charge administrative and clerical expenses to federally sponsored awards. The attached flowchart summarizes these guidelines. Note: with specific agency approval, rebudgeting to charge administrative or clerical salaries is permitted; internal rebudgeting for this purpose is not permitted.
Effective July 1, 1996 (Updated December 2008)
From OMB A-21
Exhibit C -- Examples of "major project" where direct charging of administrative or clerical staff salaries may be appropriate.
- Large, complex programs such as General Clinical Research Centers, Primate Centers, Program Projects, environmental research centers, engineering research centers, and other grants and contracts that entail assembling and managing teams of investigators from a number of institutions.
- Projects which involve extensive data accumulation, analysis and entry, surveying, tabulation, cataloging, searching literature, and reporting (such as epidemiological studies, clinical trials, and retrospective clinical records studies).
- Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences and seminars.
- Projects whose principal focus is the preparation and production of manuals and large reports, books and monographs (excluding routine progress and technical reports).
- Projects that are geographically inaccessible to normal departmental administrative services, such as research vessels, radio astronomy projects, and other research fields sites that are remote from campus.
- Individual projects requiring project-specific database management; individualized graphics or manuscript preparation; human or animal protocols; and multiple project-related investigator coordination and communications.
These examples are not exhaustive nor are they intended to imply that direct charging of administrative or clerical salaries would always be appropriate for the situations illustrated in the examples. For instance, the examples would be appropriate when the costs of such activities are incurred in unlike circumstances, i.e., the actual activities charged direct are not the same as the actual activities normally included in the institution's facilities and administrative (F&A) cost pools or, if the same, the indirect activity costs are immaterial in amount. It would be inappropriate to charge the cost of such activities directly to specific sponsored agreements if, in similar circumstances, the costs of performing the same type of activity for other sponsored agreements were included as allocable costs in the institution's F&A cost pools. Application of negotiated predetermined F&A cost rates may also be inappropriate if such activity costs charged directly were not provided for in the allocation base that was used to determine the predetermined F&A cost rates.
Sponsored projects have project periods established by the terms and conditions of the award agreements. The project period defines the time for incurring expenditures that will be invoiced and reported. Additionally, the project period defines the time during which the scope of work must be accomplished. These procedures set forth steps for managing awards that are approaching the project end dates, including requesting no-cost extensions, processing invoices and expenditure adjustments and requesting advance spending funds.
Upon award activation Rice University agrees to comply with the conditions established by the awarding sponsor for project closeout of a grant or contract. Reports required at the close of a project vary by the type of sponsored project and by sponsor. Typical closeout requirements include the timely submission of the following reports:
- Technical/scientific report, submitted by the Principal Investigator (PI) with a copy to the Office of Sponsored Research (OSR);
- Inventions report submitted by the PI to OSR;
- Financial/expenditure report(s), cost sharing report and any needed final invoice, submitted by Research and Cost Accounting (RCA) in coordination with the PI and departmental administrator (DA);
- Property/equipment report, submitted by Property Accounting in coordination with RCA.
Additional financial forms may also need to be submitted for contracts and subcontracts. These include:
- Contractor Release Form submitted by RCA after final expenditure coordination with the PI and DA;
- Assignment of Refunds, Rebates and Other Amounts submitted by RCA after final expenditure coordination with the PI and DA.
Timeliness of reporting is crucial to sound grants/contracts management to ensure compliance with sponsor requirements and reimbursement for costs incurred.
- For awards from federal agencies, these reports are due within 90 calendar days of the award expiration (project end date);
- For most federal flow-through projects, the reports are due 45-60 days after the project end date;
- For state and other awards, the deadlines vary and may be shorter.
Inability or failure to submit reports within the stipulated time frame can result in the suspension of funding, non-payment of incurred costs, a loss of the ability to submit future proposals and/or a delay in the release of future funding for the investigator and/or the University. Internal university guidelines are set to ensure that sponsor requirements are met.
The below procedures address financial reporting, including both expenditure and equipment reports. OSR should be contacted regarding any questions on non-financial reporting requirements.
The PI is responsible for the management of the award, both scientifically and financially, in accordance with the terms of the award and University policies and procedures. Expenses charged must be allowable, allocable, reasonable and consistently applied. The PI and DA must ensure that all costs are correctly recorded on a timely basis in the ledger (i.e., Banner).
Periodic reviews of costs incurred during the project period will ensure accurate interim invoicing and financial reports. They also minimize the number of costs transfers needed during the closeout period.
In order to comply with reporting deadlines, all expenditures related to the project must be processed:
- all subcontract and other vendor payments posted,
- open encumbrances closed,
- cost sharing verified, and
- the fund(s) reviewed for errors or necessary changes, including any refunds or rebates.
Any necessary corrections must post to the fund at least 15 days prior to the report due date.
Identifying projects that are ending
There is a Project End Date report available in WebApps that lists all funds with a project or budget end date within 90 days of the requested query date. (See Budget Summary in Finance queries section).
Additionally, OSR sends out Award Expiration Notices 30/60/90 days prior to the project end date. The PI should determine whether the scope of work can be completed by the end date or if an extension of the project period is necessary. If additional time is needed, the PI must process a No-Cost Extension (NCE) request through OSR. If the work can be completed within the current project period, the PI and DA should proceed with closeout.
Processing closeout entries
There is a Projection Template tool available in WebApps to assist with planning closeout transactions. (Contact Administrative Systems for access.) This tool provides a means for planning all transactions needed to proceed with closeout. These include:
- Identifying continuing funding sources for personnel currently paid on the award
- Processing needed PCard reallocations
- Completing travel envelopes
- Clearing any travel advances
- Requesting and processing final subcontract invoices
- Requesting and processing other vendor invoices
- Assigning any refunds or rebates
- Cancelling open encumbrances
Additionally, if the award has required cost sharing to be reported, the PI/DA should contact RCA to ensure all cost sharing commitments have been met. (See Policy No. 306, Cost Sharing and related post-award procedures.)
If it is anticipated that new or continuation funding will be needed to support continuing charges, an Advance Spending fund should be requested as soon as possible in the closeout process. This is especially important when a new funding source has been identified but not yet established. (The form for requesting an Advance Spending Fund is available on the OSR website). Use of an Advance Spending Fund will allow for timely moving of payroll and other continuing charges to the expected new funding source.
Stopping continuing charges
DAs are expected to process the necessary forms in a timely manner to stop continuing charges from posting after the award/project end date. These include:
- Payroll expenses
- Moved to new/continuing funds, or, if needed
- Termination of employment, including taking benefit time within the project period
- On-going user charges that default to the closing fund(s)
- Some continuing charges have default fund numbers associated with the users. The following areas should be contacted and given new default fund numbers for users associated with the ending project.
- Shared Equipment Authority (SEA)
- Chemistry Storeroom
- Telephone costs
- Copy charges
Final Financial Reports
- RCA is responsible for submitting to the sponsor all financial reports and invoices.
- After the award/project end date, RCA sends an expenditure recap to the PI and DA that summarizes the costs that have posted to the award, including any accrued expenditures that posted after the project end date but were incurred during the project period.
- If the recap identifies an adjustment is needed for overexpenditures, the department/PI will be asked to identify an appropriate funding source for the direct cost portion of the overexpenditure.
- Occasionally, the terms of a multi-year project that is awarded incrementally require a final financial report/invoice for each increment. In these cases, RCA must submit a final accounting for that funding period and/or a final invoice even when additional funding is anticipated but the project period has not yet been extended.
- If the award requires cost sharing, the recap will also include a summary of cost sharing expenditures.
- The PI and DA are to advise RCA promptly of any additional adjustments needed for pending transactions and forward copies of support for these amounts.
- It is expected that the salary amounts confirmed by the PI and DA will not change and will be so certified on the Effort Reports filed during the next reporting cycle.
- RCA will revise the expenditure amounts as needed and submit the report/invoice to the sponsor.
Timeline for Closeout Activities
|90 days prior to award end date
||60 days prior to award end date
||30 days prior to award end date
||20-25 days prior to report due date
||5-10 days prior to report due date
▪OSR sends 90-day termination notice
▪OSR sends 60-day termination notice
▪OSR sends 30-day termination notice
▪RCA sends recap of expenditure to PI and DA
▪RCA prepares and submits final financial report/invoice to agency
▪PI and DA review expenditures and technical status
▪PI considers no-cost extension (NCE) or
▪PI and DA review Projection Template and plan closeout transactions
▪PI/DA prepares NCE request or
▪PI/DA reviews transactions & encumbrances to ensure planned expenditures have been initiated
▪DA processes needed personnel and payroll changes
▪PI/DA checks on subcontract invoices
▪PI/DA submits NCE request or
▪PI/DA posts PCard and other adjustments, including reallocations and travel statements
▪PI/DA ensures payroll forms have been processed
▪PI/DA requests final subcontract invoice
▪PI/DA confirms expenditure amounts
Award terms and conditions determine the due date for final financial reports and invoices. Generally, due date information by type of sponsor and fund group* is:
Fund groups: R1, R2, R3 and R5
- Due 90 days after award/project end date
- RCA sends expenditure recap 65-70 days after project end date
Federal pass-through awards
Fund group: R7
- Varies by award, usually due 60 days after award/project end date
- RCA sends expenditure recap 35-40 days after project end date, if the report is due at 60 days
Fund groups: R0, R4, R6, R8, R9
- Varies by award
- For example, RCA sends expenditure recap 20-25 days after project end date, if the report is due at 45 days
Note: Until an amendment is received for continuation funding, the current award terms determine the due date for final financial reports and invoices. Meeting the current due date is critical to compliance and payment.
|*R fund numbers are assigned according to the type of sponsor, identified by the fund group (i.e., the first two digits of the fund number). Below is a listing of the fund groups for sponsored projects.
||Type of Sponsor
||Other Federal Agencies (e.g., DOE, EPA, DOD)
||Federal Pass-Through Funds
||State and Local Governments
||Other Private Sponsors
Some sponsors require final equipment reports to be filed at the end of a project. Property Accounting is responsible for preparing and submitting all equipment reports. They are prepared from the posted equipment charges in Banner and reviewed by RCA to ensure the amounts agree with the final equipment charges. Property Accounting forwards the final reports to the sponsor.
Questions on Financial Reporting?
Please contact Research and Cost Accounting (firstname.lastname@example.org).
Related Policies, Procedures and Forms
Policy No. 302, Cost Transfers (and related procedures)
Policy No. 304, Effort Reporting (and related procedures)
Policy No. 306, Cost Sharing (and related procedures)
Policy No. 307, Issuing and Monitoring Subawards and Subcontracts (and related procedures)
Policy No. 311, Salary Support Through Sponsored Projects (and related procedures)
Policy No. 405, Benefit Time
No-Cost Extension Request Form
Pre-Award/Advance Spending Request Form
To set up an initial award in the Banner financial system, the Office of Research Accounting requires (1) the award documents, including all exhibits and attachments, and (2) the proposal documents, which include Rice's Review and Approval Form (R&A), the proposal budget, the budget narrative, the abstract/proposal summary/statement, and the cost sharing budget (if applicable).
The Office of Sponsored Research sends the award documents via e-mail to the Principal Investigator (PI), the Department Administrator and Research Accounting. OSR provides Research Accounting with the proposal documents separately.
Notice of Action
The Banner grants and contracts module has multiple data entry screens with over 80 coding fields to be entered. (See Research Accounting Grant and Fund Checklist.) When the fund has been set up, Research Accounting sends a “Notice of Action” to the PI, Department Administrator, Chairman, Dean, and OSR that the coding for the newly awarded grant or contract has been entered into Banner and is available for data entry. The Notice also includes any special terms and restrictions of the award and indicates if cost sharing is required to be reported. A journal for the budget has been entered, but is not available on the Web until the first transaction has posted. Please review the “Notice of Action” and notify the person named in the contact box if you have any questions about the Notice of Action or any of the fields in Web Apps.
Advance Spending Fund
There are occasions when commitments or expenses need to be incurred before a fund has been established. For example, an award document has not been received but there is relative certainty that it is forthcoming. In such cases the Principal Investigator/Department Administrator can, with the approval of their Dean, request an Advance Spending Fund. Using an Advance Spending Fund will allow for proper coding of expenses and reduce the number of cost transfers and salary redistributions.
What is needed to establish an Advance Spending Fund?
- PI/Department will:
- Download the Request for Advance Spending Form (Word).
- Complete the form, being sure to include the guarantee fund. The guarantee fund will be used to cover
expenses if the project is not awarded or if some expenses are determined to be unallowable after the
award is finalized.
- Forward the completed form to OSR.
- Office of Sponsored Research will:
- Advise on the current status of the proposal.
- Forward the form and proposal information for setup.
- Research Accounting will:
- Set up the fund using the same process as that for a new award.
- Use Advanced Spending as the agency ID and as the award number in the fund title.
- Update the Banner codes and information as required after the award is received.
Advanced Spending or Pre-Award?
An Advance Spending Fund is appropriate when there is no award yet in place. Pre-Award approval is needed when an award is in place and the PI requests the the project start date be back-dated for up to 90 days. Pre-Award approval is requested via the Institutional Approval Form (Word).
“R” Fund Numbering
When a new award is received, one of the first steps is to assign an appropriate fund number. This six-digit number is used to identify the award in the accounting system as well as allow for summarized financial reporting. The first digit in the fund number represents the fund type (e.g., “D” for Designated and “R” for Sponsored Project). All funds assigned to Research Accounting begin with an “R”. The second digit indicates the agency type and is determined based upon the following criteria:
||Private foundations (excluding Welch)
||Federal agencies, excluding NSF, NASA, NIH, and DHHS, which are identified separately. Includes NEA, Air Force, Navy, Army, EPA, DOE, etc.
||NIH and DHHS
||State and Local
||State and local government, including state universities
||Private other, including private universities
The first five digits of the six-digit fund number identify the project. The parent funds ends in zero (0), and subfunds are sequential and assigned as needed.
Subfunds are separate fund numbers assigned to track specific expenses within a project. Subfunds are linked to the parent fund; they are numbered sequentially (1-Z as the last digit of the fund number); and they have the same Banner coding screens as the parent fund. The establishment of subfunds may be required by the terms and conditions of a specific award. Examples include but are not limited to:
- Participant Support costs on an NSF award
- Awards for Research Experiences for Undergraduates
- Different F&A rates for expenses within an award
A request from the PI/Department Administrator is not needed if a subfund is required by the award or if a subcontract is involved.
A request for a subfund from the PI/Departmental Administrator is needed if equipment fabrication is involved, if the PI wishes to track costs by a co-PI, or for other internal budgeting and tracking purposes.
Subfund for Subcontract to Another Institution
A subcontract is a subgrant from a Rice prime grant or a subcontract from a Rice contract to another institution, typically a university, with a defined scope of work. Research Accounting receives e-mail notification of a subcontract award from OSR, similar to the notice received for a new award. Documents required for setting up the subfund include:
- Subcontract award
- Specifies the subcontractor
- Specifies the agency awarding fund
- Specifies the period of performance
- Specifies the compensation (maximum amount to be paid by Rice)
- Specifies allowable cost and payment information
- Includes assurances
- Includes signatures by both parties
- Scope of Work
- Budget/Budget Justification from the other institution.
The budget in Banner for the subfund includes not only the direct costs authorized to be paid to the subcontractor, but also the Rice F&A costs on the first $25,000 of each subcontract.
Amendments to Awards
To amend an award, Research Accounting must receive an e-mail notice of an amendment from the Office of Sponsored Research. Research Accounting staff will then:
- Update Banner screens as needed
- Prepare a Budget Revision Notice of Amendment
- Enter a budget journal entry in Banner
- E-mail budget revision notices to department
These procedures are issued in accordance with Research Policy 306, Cost Sharing
They are intended for guidance on post-award administration of cost sharing expenditures. Cost shared resources and costs must be proposed, tracked, expensed, and recorded per Rice policy and procedures and per sponsor guidelines.
The Principal Investigator (PI) bears primary responsibility for management of the sponsored programs that are awarded to him/her. Management involves budgetary and cost compliance as well as technical compliance. This includes not only staying within the total program budget and time period, but also staying within specific budget guidelines contained in the award. While all providers of committed cost sharing are responsible for honoring their cost sharing commitments, the main/contact PI is expected to monitor and coordinate the funding and recording of cost sharing expenditures. The main/contact PI should request assistance from the Chair and Dean as needed to resolve variances between agreed-upon cost sharing commitments and funding or expenditures.
Commitments of University resources, including academic year time, must be approved in accordance with the cost sharing policy and the cost sharing proposal procedures of the Office of Sponsored Research (OSR) prior to proposal submission.
Research and Cost Accounting (RCA) will assist the PIs and department administrators (DAs) in tracking cost shared costs. A review of cost sharing procedures and reports is a part of the annual Office of Management and Budget (OMB) Circular A-133 audit and is required by the federal government.
Cost sharing is that portion of total project costs not provided by the sponsoring agency. Matching has the same meaning as cost sharing. Cost shared effort may also be referred to as contributed effort. Per OMB Circular A-110, all costs that are reported as cost sharing must be allowable, allocable, and reasonable, incurred within the project period, derived from non-federal sources, used as cost sharing for only one project, and certifiable through university accounting records.
There are three types of cost sharing: mandatory, voluntary committed and voluntary uncommitted.
- Mandatory Cost Sharing is required by the sponsor as a condition of funding. It is described in an agency's program announcement and noted in the award document of the approved budget. It must be included in the proposal as a condition of submission and receipt of the award. This type is also referred to as Required Cost Sharing .
- Voluntary Committed Cost Sharing is not required by the sponsor but has been included in the proposal in a quantifiable manner. See the OSR proposal procedures for examples of quantified voluntary committed cost sharing. Some sponsors do mot allow proposals to include voluntary committed cost sharing.
- Voluntary Uncommitted Cost Sharing is cost sharing that has been recorded in the accounting system but is neither mandatory or voluntary committed cost sharing. If a PI chooses to report voluntary uncommitted cost sharing on a project, it is recorded in the accounting system but is not reported to the sponsor.
Committed Cost Sharing includes both mandatory and voluntary committed cost sharing and excludes voluntary uncommitted cost sharing. When an award is made which includes committed cost sharing, the University has agreed to ensure that the cost sharing is funded and expended. Committed cost sharing expenditures must be identified, administered, recorded, and accounted for consistently throughout the University and reported as required by the sponsor.
Sources of Cost Sharing
The following terms are commonly used at Rice when describing the sources of cost sharing.
- In-kind: Used to describe the source of funding for A1-budgeted positions and related fringe benefits / tuition remission committed as cost sharing. This includes academic year time contributed by faculty.
- Cash: Used to describe the source of funding for positions not budgeted in A1 funds and related fringe benefits / tuition remission, as well as equipment, travel, supplies and other direct costs committed as cost sharing.
- F&A: Reflects the Facilities and Administrative (F&A) costs related to the above direct costs. This amount is not charged in the accounting system; it is tracked by RCA in the cost sharing worksheets described below.
- Third Party: Used for non-Rice cost sharing providers, both subcontractors and others, that commit cost sharing during the proposal process. A completed Third Party Cost Sharing Form (available on OSR website) must be routed with the proposal. OSR reviews cost proposals from third parties to ensure they meet OMB Circular A-110 requirements for valuation. For subcontractors, OSR includes such cost sharing commitments in award documents to them. For non-subcontractors, PIs are responsible for certifying that cost sharing commitments from them have been met. See Other Third Party Commitments of Cost Sharing below.
OSR Responsibilities for Committed Cost Sharing
OSR is responsible for reviewing proposal cost sharing commitments for compliance with Rice policy and sponsor requirements and for ensuring that needed documentation of cost sharing commitments is available. If the proposal commits cost sharing by subcontractors, OSR will ensure that subcontract award documents require the cost sharing to be certified to Rice. If there are changes in cost sharing commitments or providers, the PI should contact OSR, who will then contact the sponsor as needed. See the cost sharing proposal procedures on the OSR website.
RCA Responsibilities for Committed Cost Sharing
At the time of fund setup and budget action, RCA reviews all proposal and award documents for cost sharing commitments. When a commitment is identified, RCA activates a LOCN (location code) for the project and updates Fund Text with commitment detail in the accounting system. When RCA sends the budget action form to the department, the cost sharing comments section contains information on cost sharing commitments. RCA adds the project to its cost sharing summary database and creates a detail worksheet for the project.
In-kind cost sharing (typically faculty salaries and fringe benefits) is charged to the A1 budget of the provider. Rice-provided cash cost sharing is generally charged to a non-A1 fund that defaults to the correct program and location codes (see below). At the time of a new award with cash cost sharing, RCA requests that Current Funds set up a fund to be used for recording these cost sharing expenditures. The PI/DA is notified of the new fund number, generally a designated (D) fund. The DA of the responsible organization is responsible for processing a Budget Transfer Memo within 90 days of the start of each project year to transfer funding from each provider to the cost sharing fund(s).
To assist the departments during the award period, RCA periodically updates the project detail and summary worksheets and sends reminders to the DAs and PIs if reported cost sharing is not “on track” with commitments. When significant variances are noted, RCA will request assistance as needed from PIs, DAs, Chairs, Deans, and VPR to ensure compliance with committed cost sharing expenditures.
RCA reports cost shared expenses to the sponsor as required by the award terms and conditions and annually prepares cost sharing summary worksheet for OMB Circular A-133 audit review. When preparing the F&A cost proposal, RCA includes committed cost shared expenditures in the research base. Voluntary Uncommitted Cost Sharing is excluded from the base, per OMB guidance.
Large/multi-department projects frequently have a number of cost sharing providers across departments and schools. The sponsors of these projects also generally request annual revised budgets that may affect previously submitted cost sharing commitments. For such projects, the DA of the main/contact PI should have periodic meetings with the DAs of the other providers to ensure that cost sharing commitments are being met and appropriately recorded. Additionally, the DA of the main/contact PI is responsible for ensuring that OSR has a copy of revisions to the cost sharing commitments.
Tracking Cost Sharing Expenditures
Rice-provided cost sharing is recorded in the accounting system using IDR2 as the PROG (program code) and the R fund # as the LOCN (location code). The LOCN identifies the specific sponsored project fund for which cost sharing is being recorded. It is the responsibility of the PI/ DA to ensure that cost shared expenditures are recorded properly. Samples of such coding are provided later in this document.
Subcontractor Commitments of Cost Sharing
If a cost sharing commitment from a subcontractor is required, OSR includes the provision in the award document that invoices must include cost shared amounts. RCA periodically updates the cost sharing worksheets for amounts included on subcontract invoices. RCA will ask the DA to contact a subcontractor to provide the cost sharing amounts if they are not on the subcontractor invoices.
Other Third Party Commitments of Cost Sharing
If there are other third party cost sharing commitments in the proposal, OSR will obtain documentation from the provider that will support the value of the cost sharing. At the end of the project, RCA will request PI certification of fulfillment of the third party commitment. This form is available in the RCA forms section of the Controller’s website.
At the end of the project, RCA prepares a draft of the final cost sharing expenditures. In the event that documented cost sharing expenditures are less than the cost sharing commitments, the PI has the following options:
- provide documentation and support for additional cost shared expenditures;
- request sponsor approval through OSR to reduce cost sharing commitments; and/or
- reduce sponsored project fund expenditures to record them as cost sharing.
(From the OSR proposal procedures: “If at any time the PI becomes aware that not all of the cost sharing commitments can be met, the PI must notify OSR and RCA at once and provide a reason why the commitments cannot be met. If it is determined that a reduction is necessary, then OSR will notify the sponsor and request a reduction of the commitments. Depending on the circumstances, the sponsor may approve the request or reduce the sponsor share of the project costs accordingly.”)
RCA prepares the final cost sharing expenditures report and submits it to the sponsor as required. A copy of the final report is retained in the RCA files.
From Proposal Budget Narrative:
- The PI will contribute 10% academic year effort to this project.
- A graduate student will work on the project for the first year at no cost to the sponsor.
- The university will provide the funds required to purchase the microscope necessary to conduct the research and provide $2,000 of supplies needed to operate it.
(1) Coding of cost shared academic year time
A1 - 700000 - 60110 - IDR2 - R12345 10.00%
This indicates that a professor (account 60110) in an academic department (organization 700000) is paid from departmental funds (fund A1) and 10.00% of his/her salary is cost shared (program IDR2) to location code R12345. Automatically in Banner, fringe benefits are calculated based on the account code used. Therefore, 10.00% of this professor’s salary and fringe benefit charges would be cost shared to R12345.
These expenses are documented via the Time Allocation Report and certified on the Effort Report.
(2) Coding of cost shared graduate research assistant
D98765 - 700000 - 60850 - IDR2 - R12345 10.00%
This indicates that a graduate research assistant (60850) in an academic department (700000) is paid with funds from D98765 and 10.00% of his/her salary is cost shared (IDR2) to R12345. Automatically in Banner, tuition remission will be calculated based on the account code used. Therefore, 10.00% of this graduate research assistant’s salary and tuition remission charges would be cost shared to R12345.
These expenses are documented via the Graduate Student Payroll Authorization form and certified on the Graduate Student Salary Confirmation.
(3a) Coding of cost shared equipment
A1 - 700000 - 75240 - IDR2 - R12345 $35,000.00
This indicates that laboratory equipment (75240) was purchased with departmental funds (A1) in an academic department (700000) in the amount of $35,000.00 and cost shared (IDR2) to R12345.
This expense is documented when the Purchase Order (PO) is issued.
If the cost sharing is not documented on the PO, cost sharing information must be added after the expense is recorded in Banner by submitting an Expense and Revenue Correction form to the Controller’s Office (MS-70) using IDR2 as the program code and the correct LOCN code.
(3b) Coding of cost shared supplies
D98765 - 700000 - 72180 - IDR2 - R12345 $150.00
This indicates that laboratory supplies (72180) were purchased with funds from D98765 in an academic department (700000) in the amount of $150.00 and cost shared (IDR2) to R12345.
This expense is documented when a purchase is made of when a vendor invoice is coded for payment.
If the cost sharing is not documented on the PO or invoice, cost sharing information must be added after the expense is recorded in Banner by submitting an Expense and Revenue Correction form to the Controller’s Office (MS-70) using IDR2 as the program code and the correct LOCN code.
This type of departmental fund (D98765) can be set up to default to IDR2 – R12345 so that all expenses charged to D98765 will be recorded as cost sharing on R12345.
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These procedures are issued in accordance with Policy 302, Cost Transfers.
A cost transfer moves charges from one University fund to another.
The Principal Investigator (PI) is responsible for the management of sponsored programs that are awarded to him/her. These include federal, state, and private grants and other sponsored agreements.
In addition to technical compliance, the responsibility for budgetary compliance rests with the PI. This includes not only staying within the total program budget and project period, but also staying within specific budget limitations that may be required by the award terms and conditions. Each PI is responsible for ensuring that charges made to a particular research fund are allowed by the funding source and are directly related to the project or activity supported by that fund. The PI should carefully consider whether an expense is an allowable, allocable and reasonable cost on a given fund before the expense is incurred. In addition, the PI is responsible for reviewing monthly expenditure reports and time allocation reports on a timely basis.
Cost transfers are sometimes necessary and unavoidable; however, they should not be used as a method for routine funds management. They may be used to correct an error or to allocate expenses between closely related projects if both projects benefit directly from the expense. Cost transfers should not be requested simply to avoid over expenditure in one research fund by transferring expenses to another research fund, nor should they be used as a method to spend money because a project is nearing its end.
Cost transfers on sponsored project (Rxxxxx) funds are subject to Research Policy 302, Cost Transfers. When initiated, cost transfers must be timely, well-documented and properly approved. Unallowable or inappropriate charges that appear on a sponsored project fund must be moved to an appropriate fund promptly.
To request a cost transfer for non-salary charges involving an R fund, an Expense and Revenue Correction form must be completed and forwarded to the Controller’s Office. See Controller’s website for a copy of the form and instructions.
- Timely. In accordance with the Cost Transfers policy, cost transfers submitted later than 90 days from the end of the month in which the charge first appears on the fund or submitted later than 30 days after the end date of an award are not considered timely. Cost transfers not submitted in a timely manner must also include:
- Approval of the department chair of each department (see Properly Approved, below).
- Additional documentation if expenses are to be charged to another Rxxxxx fund (see Well-Documented, below).
- An explanation of the delay in processing the cost transfer.
- Include information on what steps are being taken to prevent future similar delays.
- Well-documented. In addition to providing information on the original posting in Banner, including entry by Banner transaction amount and Banner document # (see form instructions), a cost transfer request on sponsored project funds must include:
- A full explanation of how the error occurred. For example:
- Why the expense was originally charged to the fund from which it is now being transferred.
- What is known now that wasn’t known at the time of the original charge.
Note: See the Research and Cost Accounting forms section of the Controller’s website for sample explanations for cost transfers.
- For transfers other than simple corrections of account codes or movements within subfunds of the same project and that involve moving an expenditure to an Rxxxxx fund, also include:
- How the expenditure directly benefits the fund receiving the charge.
- A generic statement such as “to correct error” is insufficient and will not be accepted.
The direct cost portion of over expenditures in sponsored project funds may be written off to a non-R fund by using account code 72835, Write Off R Fund Over Expenditures, for both the debit and credit amounts. Such a write off does not require a detailed listing of transactions being moved. Please contact Research and Cost Accounting (email@example.com) in the Controller's Office for additional information.
- Properly Approved.
- The PI or designee must approve cost transfer requests before they are submitted. The PI or PI designee signature certifies the correctness of the proposed cost transfer.
- Cost transfers that are not timely also require the approval of the chair of each department affected by the cost transfer.
- If the PI is also the chair, approval from the Dean is required.
To request a cost transfer for salary-related charges involving an R fund, the appropriate payroll form must be submitted. There are several methods for redistributing salary charges, depending on the type of employee or student. The most common methods are the payroll re-distribution form for faculty and staff paid semi-monthly and the graduate student payroll authorization form. Please contact the Payroll Office for assistance with the appropriate method to use for needed changes. Additionally, labor charges are subject to Effort Reporting requirements. The Research and Cost Accounting website provides additional information on the Effort Reporting process.
Research and Cost Accounting will contact the department if additional information is needed to approve the cost transfer request. If the cost transfer cannot be approved, Research and Cost Accounting will notify the department via email of the reason for the action or return the original document to the department with the reason for the action.
Questions? Contact Research and Cost Accounting via email at firstname.lastname@example.org.
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These procedures are issued in accordance with Research Policy 304, Effort Reporting.
Effort reporting is a means of verifying that salaries charged to a sponsored project or program represent the effort that has been performed as specified in the award and/or the effort expended in support of a project but not paid by that project (mandatory or voluntary committed cost sharing) has been performed as specified.
The Principal Investigator (PI) is responsible for the management of
sponsored programs that are awarded to him/her. These include federal,
state, and private grants and other sponsored agreements. The federal
government requires the University to document effort charged and
committed as cost sharing in accordance with provisions in Section J10 of OMB Circular A-21, Cost Principles for Educational Institutions and PART200—UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDITREQUIREMENTS FOR FEDERAL AWARDS SubpartE—Cost Principles §200.430 Compensation-personal services.
Training is required for all administrative staff PI's in the certification process and for all first time PI's. For all faculty the training is strongly encouraged. For instructions on how to take this training, please see the Online Training Resource on Effort Certification memorandum dated February 26, 2014.
In order to ensure that salaries and wages charged to any grants or contracts are appropriate in relation to effort applied, it is necessary for the PI to review and confirm these charges periodically. Rice has chosen to do this review and certification twice every year for faculty and other employees and annually for graduate students.
Confirmation and Certification of Effort
The PI should ordinarily sign his or her own Effort Report, in addition to those reports of employees and students paid from or cost shared to his/her projects. The PI or Graduate Student’s Advisor should normally sign the Graduate Student Salary Confirmation. When this is not practical and only when appropriate, the individual who performs the work or someone who regularly oversees the work may sign, such as the laboratory or project manager. Every signer must use a suitable means of verification to confirm that the work was performed. If someone other than those listed above signs the Effort Report or Salary Confirmation, written documentation of the method of verification used by the signer should accompany the Effort Report or Salary Confirmation. The department is responsible for determining the most appropriate person to sign the certification. A process to identify the most appropriate person per individual is a future goal of the University.
Once the employee’s or student’s effort is certified on the Effort Report or Graduate Student Salary Confirmation, retroactive adjustments will not normally be permitted.
Cost transfers on sponsored project (Rxxxxx) funds are subject to Research Policy 302, Cost Transfers. When initiated, cost transfers must be timely, well-documented and properly approved. Unallowable or unrelated charges that appear on a sponsored project fund must be moved to an appropriate fund promptly. Cost transfers submitted later than 90 days after the end of the month of the original transaction or later than 30 days after an award ends will be reviewed on a case-by-case basis by Research and Cost Accounting (RCA). If the transfer is denied, notification will be made in writing.
Effort Reports and Graduate Student Salary Confirmations are printed by RCA and mailed out twice every year and annually, respectively, to departments (or organizations) in order to confirm that salaries and wages paid from or allocated to sponsored project funds (R funds) are reviewed by the PI. Instructions and a due date are included with the reports. Departmental administrators or other employees designated by the chair are responsible for distributing the reports to the appropriate certifier.
In the event that an Effort Report or Graduate Student Salary Confirmation lists two or more PIs or the work was performed for a department other than the employee’s or student’s home organization, then RCA will route the certification to the department with fiscal responsibility for the R fund. These will be labeled with instructions for the departmental administrator.
If the certifier deems that the fund number, as described by the title, and the percentage of effort (work performed) charged to the various sponsored project funds is reasonable (within + 5 percentage points) for the reporting period, then the reviewer will sign and date the report to complete the certification. In some cases, a laboratory or project manager, other direct supervisor, or department chair may review and certify the report, but the PI’s review is preferred, if available.
Should the pre-printed percentage differ significantly from the employee’s actual effort, normally defined as +/- 5 percentage points of total effort, cross out the pre-printed percentage and amount and write the correct percentage and amount to the right under ‘ACTUAL (3)’. Enter any additions in the space provided. This may require a modification to the salary charged.
To modify the salary charged for faculty or other employees, a Payroll Redistribution Form or a corrected Time Allocation Report must be completed and submitted to RCA with the properly certified Effort Report. Additional support documentation or a cost transfer justification may be required.
To modify the salary for graduate students, a Graduate Student Payroll Authorization Form must be completed and submitted to the Office of Graduate and Postdoctoral Studies. Additional support documentation or a cost transfer justification may be required.
Subsequent to proper certification, the approver will return the original document, along with any additional documentation or justification, to the departmental administrator or designee, who will retain a copy for departmental records. The departmental administrator or designee will forward the original document, along with any additional documentation, payroll redistributions, and / or justifications, to RCA by the due date.
Each report is printed with a due date. Reports are considered overdue if they are not properly completed, certified, and delivered to RCA before or on the due date. RCA will notify department chairs, deans and PIs about overdue Effort Reports within 20 business days after the effort reporting deadline. Overdue reports not returned to RCA within 30 business days after the effort reporting deadline will be considered delinquent.
As properly certified Effort Reports are returned to RCA, the analyst date stamps each report when it is received and reviews each report for the appropriate signature(s) and dates. The analyst then files each report first by organization and then alphabetically by name.
If payroll redistributions are required, RCA will monitor the process to ensure redistributions are processed as soon as possible.
Certifier / Approver: responsible individual who has first-hand knowledge of the work performed using a suitable means of verification, which can be obtained by documented discussion with the employee or PI.
Principal Investigator (PI): primary individual responsible for the technical and financial management of his/her research grant, cooperative agreement, training award, public service project, contract, or other sponsored project.
Total effort: defined as all professional activity for which the University employs an individual, whether on a full-time or part-time basis, including students who are working as teaching or research assistants. For reporting purposes, effort is calculated in percentages, not hours, with the total of all Rice effort equaling 100%. For faculty, total effort includes, but is not limited to, teaching, office hours, student advising, research activities, committee service, departmental meetings, professional development and community service at Rice or to Rice. Charges to sponsored agreements may include reasonable amounts for activities contributing and intimately related to work under the agreements, such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences. Specific short-term assignments, such as teaching a continuing education course, that are not a routine part of an individual’s employment and are compensated separately, are not considered part of “total effort” and are excluded from the effort reporting requirement.
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The Principal Investigator (PI) bears primary responsibility for management of the sponsored programs that are awarded to him/her. Management involves budgetary and cost compliance as well as technical compliance. This includes not only staying within the total program budget and time period, but also staying within specific budget guidelines contained in the award. The PI is responsible for ensuring that any committed cost sharing requirements are met and recorded in Rice's financial system. The PI is expected to approve charges to the sponsored programs or to delegate this responsibility to another person who has first-hand knowledge of the need for the expense and the appropriateness of the charges. The PI is responsible for reviewing monthly expenditure reports as well as effort reports on a timely basis. If an error is identified in these reports, it is the responsibility of the PI to initiate the necessary corrections or adjustments as soon as possible.
In assuming the stewardship of federal funds for sponsored programs, Rice has adopted certain cost guidelines and regulations that apply not only to federal awards but also establish the principles for overall university costs. These principles include consistent treatment of like expenditures as direct or indirect costs, and require that procedures be in place to ensure compliance. Further information is contained in Section 11 of the Rice Purchasing and Payment Manual (PDF).
The federal government, in Section C of OMB Circular A-21, Cost Principles for Educational Institutions, defines allowable costs as follows: “The cost of a sponsored agreement is comprised of the allowable direct costs incident to its performance, plus the allocable portion of the allowable F&A costs. The tests of allowability of costs under these principles are:
- They must be reasonable
- They must be allocable to sponsored agreements under the principles and methods provided herein
- They must be given consistent treatment through application of those generally accepted accounting principles appropriate to the circumstances and
- They must conform to any limitations or exclusions set forth in these principles or in the sponsored agreement as to types or amounts of cost items.”
Generally, the documentation and procedures required for research and non research expenditures are the same. Commitment and expenditures must comply with university purchasing policies and procedures. See Section 11 of the Rice Purchasing and Payment Manual for the procurement requirements for expenditures on sponsored project funds. See the Payment Solutions Website for links to purchasing, PCard, travel, and business meeting and entertainment policies and procedures. Costs must be incurred during the period of performance of the project. Every transaction should be adequately documented and its purpose fully explained by the person responsible for it so it can be easily understood by someone who is not familiar with either research in general or the project in particular. Avoid using acronyms.
Some direct costs by their very nature are unallowable on federal projects and most other awards. These costs include:
- Flowers and gifts
- Office morale expenses
- Alcoholic beverages
- Intramural faculty/staff meeting costs, including meals and refreshments
- Public relations costs, including advertising and lobbying expenses
- Interest expenses and fines, penalties, and late fees
- Cost transfers to cover under spending or overspending on research funds
ALLOWABLE UNDER CERTAIN CONDITIONS
Some direct costs are allowable under certain conditions. Refer to Section 11 of the Rice Purchasing and Payment Manual (PDF) for additional information.
Administrative and Clerical (A&C) Costs. A&C costs include administrative staff, office supplies, postage, monthly telephone lines, and membership dues. Under OMB Circular A-21, A&C costs are included in the F&A cost pool and are allowed as direct costs only under certain circumstances. To be allowable, they must have been clearly stated in the budget and supported in the budget narrative as an exception to OMB Circular A-21 and appear as an allowable cost on the award document. See the Funds Text note section of Web Apps for information on A&C costs on award.
Travel. Sponsors may limit specific travel costs, limit total travel costs to the approved budget, or require prior approvals for domestic and/or foreign travel. The Rice Travel Policy includes a section on charging travel expenses to an R fund. Be sure to include sufficient information to describe the benefit of the travel to the project. A phrase such as “to present paper on research results of study of XYZ at the annual meeting of the American Chemical Society” provides more information than “to attend conference.”
INTERNATIONAL TRAVEL. Rice University Travel Policy 806, Appendix A states, “Use of U. S.-flag carriers is required for all international travel chargeable to a federal award unless special conditions are met, including guidelines for code-sharing tickets. Contact the Research Accounting Office or the Office of Sponsored Research before (emphasis added) making travel arrangements which involve a non-U.S. carrier to ensure such special conditions are satisfied.” If charging airfare to a federal award, a U.S. carrier must be used not only for travel between the U.S. and a foreign city, but also between two foreign cities, unless the flight meets one of the exceptions. If a U.S. carrier does not serve the destination city, then a U.S. carrier must be used to the nearest city that does. Many U.S. carriers have expanded their foreign markets and now fly to more than one or two cities on a continent. For help in determining if a U.S. carrier serves a foreign city, visit Amadeus.net.
NOTE ON CODE SHARING: If a U.S. carrier has a code sharing arrangement with a foreign carrier, the U.S. carrier code and flight number must appear on the ticket in order to charge international airfare to a Federal award. Example: NW code shares with KLM from Houston to Paris. If the ticket shows NW#8662 the airfare is allowable on a Federal award if the ticket shows KL#662 the airfare is unallowable. U.S. carrier codes include: CO, DL, UA, NW. Foreign carrier codes include: LH, AF, BA, KL.
GUIDELINES ON USE OF U.S.-FLAG AIR CARRIERS
- The Comptroller General of the United States, by Decision B138942 of June 17, 1975, as amended March 31, 1981, provided guidelines for implementation of Section 5 of the International Air Transportation Fair Competitive Practices Act of 1974.
- Any air transportation to, from, between, or within a country other than the U.S., of persons or property, the expense of which will be assisted by this award, must be performed on a U.S. flag air carrier if service provided by such carrier is “available.”
- The following rules apply unless the result would be use of a foreign air carrier (“foreign carrier”) for the first or last leg of travel from or to the U.S.:
- A U.S. flag air carrier (“U.S. carrier”) shall be used to destination or, in the absence of through service, to farthest interchange point.
- If a U.S. carrier does not serve an origin or interchange point, a foreign carrier shall be used to the nearest interchange point to connect with a U.S. carrier.
- If a U.S. carrier involuntarily reroutes the traveler via a foreign carrier, the foreign carrier may be used.
- Exceptions. In the following situations, use of a foreign carrier is permissible:
- Travel to and from the U.S. Use of a foreign carrier is permissible if:
- The airport abroad is the origin or destination airport, and use of a U.S. carrier would extend the total travel time 24 hours or more than would travel by foreign carrier or
- The airport abroad is an interchange point, and use of a U.S. carrier would require the traveler to wait six (6) hours or more to make connection or would extend the total travel time six (6) hours or more than would travel by foreign carrier.
- Travel Between Points Outside the U.S. Use of a foreign carrier is permissible if:
- Travel by foreign carrier would eliminate two (2) or more aircraft changes en route or
- Travel by U.S. carrier would extend the total travel time six (6) hours or more than would travel by foreign carrier.
- Short Distance Travel. For all short distance travel, regardless of origin and destination, use of a foreign carrier is permissible if the elapsed travel time on a scheduled flight from origin to destination airport by foreign carrier is three (3) hours or less and service by U.S. carrier would double the travel time.”
Exception to policy is the responsibility of the Principal Investigator and department and should be documented at the time the reservations are booked.
Business Meeting Costs. Costs must meet requirements of the funding agency as well as Rice policy and procedures. They may be charged to a grant or contract ONLY if the awarding agency allows such a cost. Rice policy and procedures require that a detailed outline/agenda and an explanation of the purpose of the meeting and the relationship to the award be submitted along with the business meeting and entertainment form. No intramural meetings may be charged to a federal award.
Equipment. Costs must meet requirements of the funding agency as well as Rice policy and procedures. For equipment items costing $5,000 or more, complete the Research Equipment Procurement Form and submit it along with the purchase order to Payment Solutions. It should describe the equipment and how it will be used on the project. The PO Checklist form is used by Research Accounting to review and approve equipment POs prior to posting the expense to an R fund.
General Purpose Computer and Software Under $5,000. Any purchase requires the signature of the PI or PI designee (Department Administrator). The signature certifies that the items will be used primarily for the conduct of the research and not simply for report preparation. A General Purpose Equipment Certification is required if the payment documentation does not otherwise include needed PI/designee signature. See Forms.
Consultants, Professional Services, and Salary Reimbursement Agreements. Services must be arranged in compliance with Section 5 of the Rice Purchasing Manual. Salary reimbursement agreements must be arranged through the Office of Sponsored Research and must be signed by authorized officials of both institutions participating in the agreement. A copy of the consultant/professional services/salary reimbursement agreement, along with invoices, is to be attached to the PO or payment requests if payments total more than $2,500 and they are charged to a research fund. The agreement must describe the nature of the services rendered and the basis for the rate of pay and it requires the signature of PI or PI designee (Department Administrator). This signature certifies that:
- Services are essential and cannot be provided by Rice employees,
- A selection process has been used to secure the most qualified individual,
- The fees are appropriate.
Some agreements, for example with NSF, NASA, EPA, may be subject to a daily limit.
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