Accounting Policy for Administration of Research Grants and Contracts
Grant and contract accounting is governed by the cost principles laid out in OMB Circular A-21 which sets forth the criteria and acceptable policy for determining costs applicable to research and development, training and other sponsored work performed by colleges and universities.
Responsibilities of Principal Investigator
The principal investigator (PI) is responsible for the financial management of research accounts. This includes the monitoring of actual costs vs. award budgets. All costs posted to an account should be directly related to the performance of that specific grant or contract. The PI should also be familiar with any special conditions or terms of the grant or contract that might limit specific types of costs.
The PI should submit all accounts payable vouchers and transfer vouchers to the Office of Research and Sponsored Programs (ORSP) for approval as soon as practical but not more than 60 days after the date of cost incurrence. The PI or departmental representative must complete the necessary forms or paperwork for all transactions on the account. The PI should notify ORSP immediately but not greater than 60 days of any errors on accounts.
Research related payroll timesheets and forms must be submitted to ORSP for approval in accordance with the timelines established by the payroll office.
Responsibilities of ORSP Accounting Staff
ORSP staff is responsible for the timely review and approval of all accounts payable vouchers, transfer vouchers and payroll paperwork. In addition, ORSP is responsible for submission of required financial reports to sponsoring agencies or organizations. Collection efforts with sponsors regarding past due payment of invoices will be handled by ORSP.
ORSP staff is limited to authority on research accounts only. Please refer all questions regarding departmental issues and accounts to your departmental budget officer and/or the Controller's Office.
Handling of Costs During "Trail Out" Period
The preferred practice is that costs are posted to the proper research account immediately. However, it is acknowledged that valid costs can occur after the end date of the grant or contract. A "trail out" period of sixty days has been established to address those types of occurrences. All final corrections or transfers must happen within the "trail out" period. After that point the account will be frozen and any further costs will be posted to the account designated on the Review and Approval Form that is signed by the PI at the proposal stage.
Handling of Overruns
The PI will have thirty days after notification by ORSP to correct any overruns on research accounts. If a correction is not received within that time period the account will be frozen and the overrun will be transferred to the PI's department account. Any further expenditures on that account will also be posted to the account designated on the Review and Approval Form that is signed by the PI at the proposal stage.
Please keep in mind that Circular A-21 states, in part, "Any costs allocable to a particular sponsored agreement may not be shifted to other sponsored agreements in order to meet deficiencies caused by overruns or other fund considerations, to avoid restrictions imposed by law or by terms of the sponsored agreement, or for other reasons of convenience." Overruns cannot be treated as bad debts by ORSP and must be covered by either departmental or flowback accounts.