Roles and Responsibilities
Overview
The University is legally accountable to the sponsor as the official recipient of a grant, contract
or cooperative agreement; however, the principal investigator/ project director (PI), acting
through the department/school/college, is responsible for the proper fiscal management and
conduct of the project. To assist the faculty member in this very important responsibility, the
University provides supporting administrative services and has established procedures to help
meet both sponsor and University administrative requirements. The University is, ultimately,
legally and financially responsible and accountable to the sponsor for the performance of the
activity funded and the proper use of funds. However, without the full cooperation and vigilance
of the PI, the department, and the college the University would fail in its stewardship role. In
the truest sense, therefore, the sponsored programs process is a joint effort between the PI,
the department, the college and the University. Each must do their part well in order to achieve
success.
The Vice President for Research is designated as the Institutional Official who has the
authority to deal directly with funding agencies, both federal and non-federal, relating to any
aspect of externally funded activity at Kent State University. The Division of Research
promotes the creation and maintenance of a University environment that encourages and
supports research productivity and compliance. The Vice President for Research is
responsible for directing and guiding KSU’s research mission and for oversight of the Division
of Research where, among other things, policies, procedures, and business decisions related
to research and sponsored project administration are formulated and monitored.
The offices of Sponsored Programs and Grants Accounting work cooperatively with the PI and
the sponsoring department in the administration of funded projects. They will assist in
structuring and implementing operating procedures to meet program administration
obligations, but they cannot be responsible for day-to-day administrative tasks for individual
programs. Principal investigators/project directors are ultimately responsible for project
management.
Grants Accounting is a unit of the Controller’s Office and oversees the accounting and
financial management aspects of grants and contracts for all eight Kent State campuses.
Grants Accounting has the following specific responsibilities:
 Establishes, maintains (includes budget input), and terminates sponsored project
funds/indexes in the financial accounting system (Banner)
 Notifies PI and appropriate parties of sponsored project funds/indexes creation
 Shares responsibility with Sponsored Programs for the formulation, implementation and
interpretation of policies and procedures regarding sponsored projects
 Prepares and submits billings to sponsor on a timely basis
 Manages the collection of grant funds, Letter-of-Credit (LOC) draw down of funds and
sponsored project accounts receivable
 Informs PI and department of payment problems with sponsors
 Coordinates the preparation and submission of financial reports to the sponsoring
agency
 Monitors grant expenditures, for allowability and allocability
 Reviews purchase orders, check requisitions and salary forms
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Processes cost transfer requests and journal entries
Reviews and processes payment of approved subrecipient invoices
Monitors the fulfillment of cost share obligations
Monitors program income
Oversees the administration of the effort reporting function
Monitors overdrafts of sponsored project funds/indexes and coordinates with
department to ensure timely resolution
Prepares the indirect cost allocation entry at year-end based upon University indirect
distribution agreement
Monitors subrecipient A-133 audit reports
Assists with the development and negotiation of the Facilities and Administrative rate
agreement with the University’s cognizant federal agency, the Department of Health
and Human Services
Assists with the government, private sponsor and public accounting firm audits
Prepares various institutional reports and surveys
Provides principal contact for sponsor fiscal officers
Sponsored Programs is a unit of Research and Sponsored Programs and assists the PI with
the implementation and management of the funded project. The staff serves as a resource for
guidance on all aspects of administration of funded projects.
Sponsored Programs has the following specific responsibilities:
 Reviews, approves, and submits proposals on behalf of the institution
 Negotiates contracts and financial arrangements and serves as a liaison with sponsors
throughout the life of the project
 Guides PIs in interpretation or clarification of federal regulations, funding agency
requirements, award terms, and University policies
 Initiates paperwork to establish a sponsored project fund/ index account for the project
 Develops the project spending plan that allocates the approved budget to University
expenditure accounts and serves as the budget for the sponsored project fund/index
 Provides guidance with administrative issues that may arise including change in level of
effort of key personnel, change in budget or change in scope of work that may require
sponsor approval
 Administers the Organizational Prior Approval System as delegated by Federal
Expanded Authorities to the University including grantee-approved no cost extensions
and budget revisions
 Reviews and approves appointment forms for employees supported by sponsored
projects
 Reviews and approves cost transfers and salary distribution revision forms submitted
more than 90 days after the original charge
 Provides information on copyright and patent procedures, export control, reporting
requirements and closeout procedures
 Completes intellectual property and fixed asset reporting
 Prepares and administers subcontracts and subawards
 Works with Institutional Advancement and the University Foundation to determine
Sponsored Project/Gift decisions.
2 Department/School/College
Considered an integral part of a department’s program and resource base, funded programs
must be monitored by the department head. Project over-expenditures and audit
disallowances are ultimately the responsibility and burden of the home department.
Department/School/College has the following specific responsibilities:
 Ensures the PI follows University policies and assumes project administrative
responsibilities
 Reviews and authorizes appropriate forms initiated by PI for payroll authorizations, new
hires, purchases, cost transfers, and other related grant expenditures
 Maintains accurate departmental records that document and verify expenditures
charged to the sponsored project fund/index made on purchasing cards, travel
reimbursements and other electronic transactions
 Assures the appropriate indirect cost rates are being requested in sponsored projects
budgets
 Assists the principal investigator in utilizing the Flashline reports
 Monitors any cost sharing commitments, along with the source of the cost share.
Assures necessary commitments will be in place prior to the award and appropriately
documented in the cost share fund/index
 Monitors project expenditures and use of funds through Banner and associated
FlashLine reports
 Ensures costs are within sponsor and University guidelines
 Assigns correct expenditure accounts to check requests, p-card reconciliations, cost
transfers, etc.
 Notifies the PI of any changes in Kent State University policies and procedures
 Provides oversight on all aspects of program income
 Obtains a thorough understanding of direct, unallowable, and indirect costs
Principal Investigator
The PI has primary responsibility for day-to-day direction and financial and administrative
management of the project operating within University policy and funding agency
requirements. The grant index will be in the name of the PI and his/her signature will be
required on any University forms that require approval. It is University policy that the PI must
be a continuing full-time faculty or staff person. The PI is responsible to the sponsor, the
department, the college, and the University to ensure that the requirements of the sponsored
project are met and the policies of the University are followed.
PI has the following specific responsibilities:
 Manages and conducts the project to meet project goals and objectives in a timely
manner while adhering to federal regulations, funding agency guidelines, and
University policies and procedures
 Understands the terms and conditions of the award/agreement, including any special or
unusual conditions
 Manages the financial aspects of the project, ensuring that all charges to the sponsored
project fund/index are necessary to accomplish the goals of the project and all
personnel charged to the index are working on the project. The PI has primary
responsibility for determining whether a cost benefits a project.
 Initiates and provides programmatic justification of expenditures of the project budget
 Approves payments of subrecipient invoices in a timely fashion
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Monitors expenditures by regularly accessing and reviewing the “Grant Report by
Principal Investigator” report, the “Labor Distribution” report, and the “Transactions”
report for the project. These are available on the “My Action Items” tab on the Flashline
web site. Any errors and/or unauthorized charges should immediately be brought to
the attention of the grant accountant for investigation/resolution. (See Monitoring Grant
Expenditures)
Conducts the project using the highest ethical standards and declares any potential
conflicts of interest for themself or any individual involved with the project that would
affect the conduct of the project. Any potential conflicts of interest shall be disclosed to
Sponsored Programs and a Conflict of Interest Management Plan enacted when
necessary.
Cooperates with Sponsored Programs to develop the project spending plan that
allocates the approved budget to University expenditure accounts and serves as the
budget for the sponsored project fund/index.
Ensures that any cost sharing commitments made in the proposal budget are met and
appropriately documented.
Recruits and hires personnel on the project following University policies and
procedures including affirmative action.
Oversees the work of all personnel, including students, utilized on the project.
Ensures compliance with the requirement that salaries and wages paid with funds from
sponsored programs are reasonable in relation to service actually performed on the
project. This is an effort certification report prepared monthly (classified and student
employees) or each semester (faculty and unclassified personnel) Signing of this
document certifies that employees performed at the level of effort budgeted and
certifies this on the "Effort Certification Report" distributed by Grants Accounting.
Consults with Sponsored Programs to ensure that necessary approvals have been
obtained for budgetary and programmatic changes that may be necessary during the
project. This would include no-cost extensions, budget revisions, change in level of key
personnel, and other programmatic changes and/or supplemental funding.
Prepares and submits technical reports and any other required deliverables on a timely
basis with copies to Sponsored Programs to be placed in the official award file. Fiscal
reports are prepared by Grants Accounting based on actual documented expenditures
and sent to funding agencies.
Ensures that all project members are familiar with and abide by the federal and
University compliance policies pertaining to human subjects in research; animal care
and use; radiation safety; laboratory safety; hazardous substances; use of recombinant
DNA; and related required training.
Ensures that project members understand and comply with intellectual property and
publication clauses of the sponsored project. Inventions and copyrightable material
produced under sponsored projects must be governed by the specific terms of the
award received from the sponsor and must be handled in accordance with University
policy.
Submits grant proposals to Sponsored Programs and other review bodies in a timely
manner to allow for necessary review and approval before submission.
Participates in training regarding University policies, compliance issues, proposal
improvement, and agency specific issues.
Keeps organized records of paperwork for audit purposes or in case of questions.
Obtains a thorough understanding of direct, unallowable, and indirect costs.
4 Office of Internal Audit
The Office of Internal Audit exists to serve as an independent appraisal agency. As a service
to management, the department examines and evaluates Kent State University's activities with
the goal of improving the efficiency and effectiveness of these activities. The office also serves
as the liaison between the University and the University's independent public accountant.
Internal Audit has the following specific responsibilities:
 Determines the reliability and integrity of information; (i.e., evaluating the internal control
systems and the integrity of financial and operating information produced by those systems)
 Determines whether compliance exists with policies, procedures, laws, and regulations
 Determines if assets are safeguarded and verify the existence of those assets
 Appraises the economy and efficiency of resource utilization (monetary and manpower)
 Reviews operations or programs for consistency with established management goals and
objectives
 Assists members of our organization in the effective and successful performance of their
responsibilities by providing them with analyses, appraisals, recommendations, and other
pertinent information concerning the activities being reviewed.
1/17/2012
5 Administration of Sponsored Projects
Overview
The University is legally accountable to the sponsor as the official recipient of a grant, contract
or cooperative agreement; however, the PI, acting through the department/school/college, is
responsible for the proper fiscal management and conduct of the project. To assist the faculty
member in this very important responsibility, the University provides supporting administrative
services and has established procedures to help meet both sponsor and University
administrative requirements. Without the full cooperation and vigilance of the PI, the
department, and the college, the University would fail in its stewardship role. In the truest sense,
therefore, the sponsored programs process is a joint effort between the PI, the department, the
college and the University. Each must do their part well in order to achieve success.
The Vice President for Research is designated as the Institutional Official with the authority to
deal directly with funding agencies, both federal and non-federal, relating to any aspect of
externally funded activity at Kent State University. The Division of Research promotes the
creation and maintenance of a University environment that encourages and supports research
productivity and compliance. The Vice President for Research is responsible for directing and
guiding KSU’s research mission and for oversight of the Division of Research where, among
other things, policies, procedures, and business decisions related to research and sponsored
project administration are formulated and monitored.
The Offices of Sponsored Programs and Grants Accounting work cooperatively with the PI and
the sponsoring department in the administration of the funded project. This manual has been
designed to serve as a reference for all personnel who have any involvement in, or oversee
faculty or staff who administer, funded projects.
Grants Accounting is a unit of the Controller’s Office and oversees the accounting and financial
management aspects of grants and contracts for all eight Kent State campuses. Sponsored
Programs, working with Grants Accounting, assists with the implementation and management of
the funded project.
Most University policies have been established to comply with State and Federal laws and
regulations. Federally funded projects are also impacted by the U.S. Office of Management and
Budget (OMB) Circulars A-21, “Cost Principles for Educational Institutions” (2 CFR Part 220)
and A-110, “Uniform Administrative Requirements for Grants and Other Agreements with
Institutions of Higher Education…” (2 CFR Part 215) and A-133, “Audits of States, Local
Governments and Non-Profit Organizations,” as well as specific terms and conditions of the
award. In the absence of applicable federal or sponsor regulations or guidelines, Kent State
University policies and procedures apply. PIs should be aware that when federal, sponsor,
and/or University regulations overlap, the most restrictive regulations apply. The PI is
responsible for reviewing federal, sponsor, University, and departmental guidelines, policies,
and procedures that are applicable to each project, and is responsible for compliance
throughout the life of the project.
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What is a Sponsored Project?
A sponsored project is defined as any externally funded research or scholarly activity that has a
defined scope of work or set of objectives. These objectives provide a basis for sponsor
expectations. Sponsored projects involve research, demonstration, professional development,
instruction, training, curriculum development, community and public service, or other scholarly
activity involving funds, materials, other forms of compensation, or exchanges of in-kind efforts
under awards or agreements. The presence of any one of the following conditions normally
identifies the activity as a sponsored project:
•
•
•
•
•
•
•
The proposal is submitted in response to an RFP (request for proposals) or similar
solicitation. All proposals are to be submitted via Coeus for review and approval.
The proposal commits the University to a specific line of scholarly or scientific inquiry
typically documented in a statement of work to be performed.
The proposal includes a set of objectives which provides a basis for sponsor
expectations.
The proposal commits University resources, such as personnel effort or use of
equipment, facilities, or other resources.
The proposal includes a detailed budget.
The proposed project involves the use of human subjects, laboratory animals,
radioactive or hazardous materials, recombinant DNA, carcinogens, pathogens, or
proprietary materials.
There is a written agreement for a commitment of resources between a sponsor
(person, corporation, foundation, or government agency) and the University.
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•
•
•
•
•
•
•
There is a specified period of performance, typically defined by “start” and “end”
dates.
The sponsor requires deliverables stated in an agreement, such as reports, financial
accounting, or intellectual property ownership.
The award includes conditions for specific formal fiscal reports and/or invoicing.
The award restricts or monitors publications or use of results or requires protection of
confidential information.
The award provides for the disposition of tangible or intangible property that may
result from the project such as equipment, records, formal activity reports, theses
and dissertations, rights in data, software, copyrights, inventions or research-related
materials.
The award specifies fiduciary responsibilities such as adherence to a line item
budget, project audit, payment contingencies, and the return of any unexpended
funds at the end of the project.
The sponsor is involved in making decisions regarding project performance or stands
to derive benefit from the work performed.
Sponsored awards are made to the University or Kent State University Foundation on behalf of
the PI, who is primarily responsible for carrying out the requirements of the award.
In developing a proposal and administering an award, the PI represents the University and is
responsible for upholding the high standards expected of University projects. The PI is
responsible for obtaining all required University approvals by submitting the proposal through
Coeus. The PI also serves as fiscal officer of the project, with all the attendant responsibilities of
project fiscal management.
Sponsored projects are subject to facilities and administrative costs (F&A) at the University’s
rate applicable to the type of project being conducted. If the sponsor has a published federally
negotiated policy, uniformly applied, prohibiting or restricting the payment of F&A costs, the
University will accept the reduced F&A rate in accordance with the sponsor’s policy. This policy
does not apply to for-profit sponsors that are expected to provide full F&A recovery.
In cases where there is a question whether a particular project should be treated as a
sponsored project contact the Director of Sponsored Programs for guidance.
Notification and Negotiation of Award
The notice of award is typically sent from the funding agency to the Sponsored Programs office.
A copy may or may not be sent from the agency to the PI. In some cases when the anticipated
award is less than the amount requested, the agency's program officer will contact either the PI
or the Sponsored Programs office to negotiate a change in budget and, if necessary, scope of
work.
If the PI determines that the proposed work can be accomplished for the renegotiated amount
proposed by the agency, a revised budget will be required. The Sponsored Programs office will
assist in preparation of the budget and submission to the agency. In the case of a significant
budget reduction, a reduced scope of work based on the reduced budget must also be
3
described and submitted to the agency. On no occasion should a PI negotiate directly with
sponsor staff regarding a project. PIs are not empowered to represent the University, and
cannot make commitments regarding cost sharing, waiver of facilities and administrative (F&A)
costs, or use of other University resources such as space or personnel.
For all NSF awards, the revised budget and budget impact statement are completed by the PI
on FastLane and forwarded to the Sponsored Programs office for endorsement and submission
to NSF.
Award Acceptance
The grant award or contract should be sent to Sponsored Programs. The Director is authorized
to accept awards on behalf of the University. Prior to official acceptance of a grant, contract, or
subaward, the reporting requirements and terms and conditions imposed by the grant/contract
agreement are reviewed. Unusual requirements and/or special conditions are noted and
communicated to the PI with a copy of the award notice.
Collaborative sponsored projects involving other universities and organizations require a
subaward outlining expectations, budget, reporting requirements, etc. When Kent is the prime
recipient of an award, Sponsored Programs prepares the subaward document(s), secures
appropriate investigator, director, and University endorsements, and submits to the cooperating
institution for execution.
When Kent is the subaward recipient, the prime recipient prepares the subaward documents.
Sponsored Programs reviews the terms and conditions, negotiates objectionable terms when
necessary, secures appropriate University endorsements, and returns the fully executed
agreement. Copies of all agreements are distributed to the PI and other University offices as
appropriate.
Project Spending Plan
Following acceptance of an award, Sponsored Programs prepares a Spending Plan that
translates the approved budget into the University account codes against which expenses will
be charged. This spending plan is entered into the Banner information system as the budget
displayed on the report entitled “Grant Report by Principal Investigator,” and is available on-line
through Flashline. A copy of the spending plan is sent to the PIs, the Department Chairs, and
the Business Manager and/or Department secretary.
If the approved budget is substantially different from that in the proposal, the PI must work with
the Sponsored Programs staff to determine changes in budget categories so that the spending
plan accurately reflects planned expenditures. The spending plan will also show the expenses
to be cost-shared by the University, when required.
Budget Revisions
If at any time during the project period the PI anticipates expenses will differ significantly (10%
variance) from the approved budget, a request to revise the budget must be sent to Sponsored
Programs. This is accomplished through submission of an Institutional Prior Approval Form,
available from the Forms Library on the Sponsored Programs website. This form requires a
description of the amounts to be reallocated and a justification describing the benefit to the
project. Depending on sponsor requirements, Sponsored Programs will then revise the
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spending plan and send it to Grants Accounting to input into the Banner system. Copies will also
be distributed as above.
Project Initiation
Upon acceptance of a grant or contract, Sponsored Programs forwards the spending plan to
Grants Accounting in the Controller's Office, along with a Request for New Restricted Fund
form. A unique 6-digit restricted grant index is assigned to the project. A cost share index is also
established if University funds have been committed in support of the project. The Request for a
New Restricted Fund form, containing the assigned grant index, fund, organization and program
number(s) is sent directly to the PI and includes the name of the grant accountant responsible
for the restricted fund. All financial transactions related to the project are to be charged directly
to the appropriate grant index in a timely manner.
Introduction to FOAP
The Banner Finance chart of account structure is based on fund accounting principles. The
chart of account elements in Banner Finance are: fund, organization, account, and program.
The chart of account elements are known as "FOAP".
What is a FOAP?
Fund – (Where) A six character, hierarchical (roll-up) code that identifies a self-balancing set of
accounts and the type of funding (Education & General – E&G, Designated, Auxiliary etc.). Each
grant will have its own fund.
Organization – (Who) A six character code that identifies a budgetary or department unit.
Account – (What) A five character code that identifies revenue source, balance sheet and
expenditures. Account will be structured to have sight recognition for different account types
(revenue, salary, expenditure, etc.). Account will also have roll-up capability for reporting.
Program – (Why) A four character code with roll-up capability that identifies a function for
expense categories (research, academic support, instruction, etc.)
The Index, although not part of the FOAP, plays a large role in data entry. Consider an index as a
convenience tool, replacing the need to enter the entire FOAP string, generally, with the exception of
account. The index is a six digit number. The first number of a grant index will always be “4”.
The first number of a cost share index, effective July 1, 2011 will start with a “C” followed by five
digits.
Effective July 1, 2011 grants will begin with the following sequence:
“40XXXX” – Letter of Credit Grants
“41XXXX” – Kent Campus
“42XXXX” – Ashtabula Campus
“43XXXX” – East Liverpool
“44XXXX” – Geauga Campus
“45XXXX” – Salem Campus
“46XXXX” – Stark Campus
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“47XXXX” – Trumbull Campus
“48XXXX” – Tuscarawas Campus
A new index and FOP will be assigned to the grant for each new grant year during a multi-year
grant, unless the award automatically carries forward at the end of the grant year.
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Direct Costs
Expenditures on sponsored projects should go through normal departmental approval procedures. All
expenses charged to a sponsored project must be reasonable, allowable, allocable and necessary for the
conduct of the sponsored project. An expenditure that would not be allowable with university funds
would not be allowable on a sponsored project. Furthermore, some funders impose greater restrictions
than University policy on how sponsored project funds may be spent.
The allowability of costs is determined by university policy and federal regulations. University policy is
governed by State of Ohio law. Federal cost principles apply to grants, contracts and cooperative
agreements. These cost principles are detailed in OMB circular A- 21, “Cost Principles for Educational
Institutions” (2 CFR Part 220).
All charges to a sponsored project must be reasonable in nature; directly benefit the sponsored project;
reasonably correlate to the project’s timeline; treated in a manner consistent with other costs of the
same type; and in conformity with applicable governmental and/or sponsor regulations and university
policy. When there are inconsistencies the most restrictive regulations of federal, state, university or
agency must be followed.
Definition of Direct Costs
Direct costs are those costs that can be identified specifically with a particular sponsored project, or that
can be directly assigned to such activity relatively easily with a high degree of accuracy. Direct Costs
should factor in any costs that reduce or offset direct cost amounts, such as rebates, discounts, etc.
Summary of Criteria for Determining Allowability of Direct Costs
For purposes of determining whether budgeting or charging a certain direct cost on a sponsored project
would be appropriate, principal investigators, departmental business officers and/or grant
administrators should be familiar with the criteria used to define "allowable direct costs." The cost must:
1. Be reasonable, i.e., the cost is generally recognized as necessary for the performance of
the project and is one that a prudent person would consider reasonable given the same
set of circumstances;
2. Be allocable to the sponsored project, i.e., the cost is incurred for the benefit of only
one project, or the item can be easily assigned to multiple benefiting projects. A specific
project may only be charged that portion of the cost that represents the direct benefit
to that project
3. Be treated consistently with other similar costs incurred in like circumstances in
accordance with generally accepted accounting principles; and
4. Conform to any limitations/exclusions stated in generally accepted accounting
principles or in the sponsored agreement, i.e., the cost must be allowable and not
designated as unallowable by regulation or sponsored project specific award conditions.
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Determination of Cost Allowability
Cost reflects conservative action a
prudent person would take under
similar circumstances
Reasonable
Cost benefits the project and the
amount charged is in proportion to
the benefit
Allocable
Not prohibited by law, regulation,
University policy, or the award
terms, and within the project
period and budget.
Specifically identifiable with a
project and consistent with
University practice
NO
Y
E
S
NO
Y
E
S
Allowable
NO
Y
E
S
Consistent
Treatment
NO
Do Not Direct
Charge on
Project
Y
E
S
May Direct
Charge to
Sponsored
Project
YES
Sponsor Funds
Available
NO
May be a
Direct Charge
to Cost Share
Cost Benefits Two or More Projects
If a cost benefits two or more projects or activities in proportions that can be determined without undue
effort or cost, the cost should be allocated to the projects based on the proportional benefit. However,
this allocation cannot be used to eliminate cost overruns.
Examples of Allowable Direct Costs
Salaries, Wages and Fringe Benefits – Salaries, wages, and fringe benefits of personnel working directly
on the sponsored project, such as faculty, postdoctoral associates, graduate assistants, and other staff,
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are allowable as are the related fringe benefits. Current employees who will be assigned to the
sponsored project activity will need to have revisions made in their appointments to reflect their effort
on the sponsored project. When new employees are to be hired the PI, working through the
department, must comply with Human Resources policy and procedures.
As a standard rule, secretarial and clerical personnel are not allowable costs as they are included in the
indirect cost rate calculation. Only when such positions have been requested and justified in the
proposal budget and approved in the award can they be charged to a sponsored project.
Certification that employees paid with sponsored project funds actually worked on these funded
activities is required. Periodically, either monthly (hourly personnel) or at the end of each semester
(faculty and professional staff), the PI is responsible for ensuring the Effort Certifications are reviewed,
signed and returned.
Supplies/Services – Purchases that are necessary for performing the sponsored project’s scope of work
and are allowable should be charged directly to the sponsored project fund/index whenever possible.
Receipts for purchases that appear on monthly purchasing statements are to be retained by the
department for audit purposes. Copies of receipts should be maintained by the PI and the department.
Details about payment processing procedures along with University payment forms are available here.
Travel – Travel costs for KSU employees are reimbursed to the traveler and charged to the sponsored
project fund/index using the on-line Expense Statement available as a workflow in the My Action Items
tab in Flashline. All travel must conform to KSU travel regulations and be submitted for reimbursement
upon completion of travel. Expense statements submitted for reimbursement must specify how the
travel directly benefitted the sponsored project and include original receipts for anything over $25.00
(or less if required by the sponsoring agency). An official conference document that indicates the lodging
rate for that site must also be included. Reimbursement for lodging, meals and mileage are in
accordance with KSU policy. Travel by air is at the lowest fare possible and must follow the Fly America
Act. All current rates can be found here.
Consultants /Independent Contractors – The services of consultants may be required to accomplish a
specific portion of the project work. The consultant may be a member of a profession or a person
possessing special skills who is not a Kent employee. Ordinarily a consultant may not be a university
employee, Funding agencies allow consultants if their area of expertise and anticipated cost are included
in the proposal.
There is an online Independent Contractor Determination Form that must be completed before the
services are provided. An Independent Contractor Agreement must be completed outlining the services
to be performed. The consultant will submit an invoice when the services are provided. Periodic
payments can be made as necessary. However, prepayment for a service is not possible.
To pay the consultant the following must be submitted to Accounts Payable:
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1.
2.
3.
4.
5.
Check Request form signed by PI and Department Chair
Copy of approval for the Independent Contractor Determination
Invoice from Consultant
Ohio New Hire Reporting Form
OPERS Independent Contractor form
Foreign nationals can only receive payment if their visa status allows the receipt of such payment. For
further information contact the Payroll Office at 672-8641.
Details about payment processing procedures along with University payment forms are available here.
Equipment – Equipment is defined in accordance with University policy as an article of personal
property having a useful life of more than a year and a minimum acquisition cost of $2,500. When
special purpose equipment is specified in the proposal budget, further approval is generally not
required. If the approved budget does not detail the purchase, prior approval must be sought through
Sponsored Programs, using the Institutional Prior Approval form. Documentation of the approval must
be provided to Grants Accounting. In accordance with University policy acquisition of special purpose
equipment costing in excess of $25,000 must be in compliance with the bidding process.
Special purpose equipment is used only for specific research, medical, scientific, or other technical
activities and is an allowable cost to a funded project. General purpose equipment is not limited to
specific research purposes and cannot be charged to a sponsored project fund/index without specific
approval using the Indirect Cost Charge Exception form. Examples of general purpose equipment would
be computers, office machines, furniture, air conditioners, and vehicles.
Other costs - Other costs that are typically allowable include subawards, repairs, maintenance, fees and
services, long distance telephone expenses, copying services, and postage services used in the
performance of the project, service/maintenance agreements on capital equipment approved by the
sponsor (or internally approved if allowed by the sponsor).
Examples of Non-Allowable Direct Costs
Unallowable costs are outlined in the OMB circular A- 21. Selected unallowable costs are listed below.
Some costs may be allowable dependent upon the specific objectives of the sponsored project:
Advertising costs are unallowable unless they are necessary to meet the requirements of the sponsored
project. Allowable costs might include advertisements for recruitment of grant personnel; subjects for
research; and procurement of goods or services.
Airfare in excess of the lowest available commercial airfare or customary standard coach airfare, except
in special circumstances such as compliance with the Fly America Act.
Alcoholic beverages unless directly related to the research objectives of a sponsored project.
Alumni activity
4
Bad debts/over expenditures on other sponsored agreements
Commencement
Contingency provisions
Depreciation reserves
Donations or contributions
Entertainment costs unless specifically allowed by program regulations
Food unless on travel status
Gifts
Goods and services for personal use
Housing and personal living expenses unless on travel status
Insurance and Indemnification
Interest
Lobbying
Losses/over expenditures on other sponsored agreements
Memberships, subscriptions, and professional activity costs. (Institutional memberships and
subscriptions are allowable).
Postage/Copying –Routine mailings and copying are ordinarily not allowable charges to sponsored
projects. Projects that have specified and justified the need for these items in the proposal as essential
to the project can be charged to the sponsored project fund/index (an example would be a mass mailing
to subjects). These expenses should be incurred at an external service
Pre-agreement costs - Costs incurred prior to effective date of sponsored agreement unless specifically
approved by sponsoring agency.
Public relations
Salaries of individuals engaged in routine departmental or administrative work that benefits all activities
of the department (instruction, research, training, public service, etc.), i.e., there is no direct relationship
to a specific sponsored project's scope of work.
Selling and marketing costs
Severance costs in excess of Kent’s normal severance pay policy
5
Student activity costs unless specifically approved in program regulations
Supplies and materials - Office supplies that are normally used in the general administrative support of
a project may not be charged to the award. Office supplies that are used for project-specific activities
outlined in the proposal may be included in the budget and charged to the project. Because many types
of office supplies are used for both general administrative support and project-specific activities, it is
important that these items, when included in the budget, be justified in terms of their relevance to the
methods used in conducting the project. Supplies and materials for routine departmental or
administrative activities that benefit all activities of the department (instruction, research, training,
public service, etc.), i.e., there is no direct relationship to a specific sponsored project's scope of work,
are not allowable. An example would be general office supplies. Also typically unallowable are general
office items with multi‐functional use such as office computers, fax machines, answering machines,
staplers, hole punches, filing cabinets, chairs, desks, calculators, waste baskets, etc., that do not have a
direct relationship to a specific sponsored project's scope of work.
Telephone – Basic telephone service is ordinarily not allowed as it is part of the indirect cost rate
calculation. Only the cost of toll calls associated with the specific project can be charged to the
sponsored project. The PI must keep a log as documentation that supports the charge to the sponsored
project fund/index. The cost transfer request should be done monthly (see cost transfer section of the
manual). Cell phone service is only permissible when authorized by the sponsored project. Personal use
of the phone is not allowed. Documentation of the business use of the phones must be approved by
sponsored programs annually.
Other costs such as travel, repairs, fees and services, local telephone expenses, copying and postage
that are for routine departmental or administrative use, and do not have a direct relationship to a
specific sponsored project's scope of work.
Exceptional Circumstances - Non-Allowable Direct Costs
Justification and approval is required to direct charge administrative and clerical salaries and other
administrative-type expenses. In addition to meeting the definition of exceptional circumstances, costs
must be specifically identifiable to a particular sponsored project, be reasonable, allowable and
allocable. A Direct Cost Charge Exception form should be completed and approved by the Department
and Sponsored Programs.
Purchase of Personal Computers and Electronic Devices on Sponsored Projects
As a recipient of federal funds, Kent State University is required to adopt costing policies in conformance
with Federal rules and regulations. The University's cost accounting practices are declared in the
required filing of its Disclosure Statement (called the DS-2) to the audit agency of the US Department of
Health and Human Services The DS-2 defines costs that can be directly charged to sponsored projects as
being allowable, allocable, reasonable, and consistently applied. Costs that support sponsored projects
on an indirect basis are also defined. Additional applicable Federal guidance in this area is provided by
OMB Circular A-21, as well as Circular A-110, “Uniform Administrative Requirements for Grants &
6
Agreements With Institutions of Higher Education.” In general, personal computers and other electronic
devices are not an allowable direct cost.
This statement is intended to help Principal Investigators and their staffs understand the appropriate
costing treatment of personal computers and other electronic devices in the context of existing
University policy as well as emerging Federal agency guidance. The acquisition of computing and
electronic devices must meet the criteria of being allowable, allocable, reasonable, and consistent
application such that the equipment can clearly be shown to directly benefit the achievement of
required sponsored projects objectives. The Federal government, through audits of universities, specific
denial of requests in notices of award, and information dissemination at professional meetings such as
the Federal Demonstration Partnership and Council of Governmental Relations, has consistently
apprised the research community that it does not consider personal computers and electronic devices
to be an appropriate direct cost to sponsored projects. This is because general purpose computing
support is considered to be an administrative cost covered by F&A reimbursement.
Because computers and electronic devices are generally used for many different activities (for example,
instruction, research, administration, email, personal use), the default presumption is that these devices
cannot meet the threshold requirements to allow the direct charging of their acquisition to a sponsored
project.
In all cases, purchases must conform to the cost principles for educational institutions described in the
OMB Circular A-21. Costing guidelines specify that charges for computers and electronic devices, as with
all other charges directly charged to Federal awards, must meet the following conditions:
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•
•
They must be necessary for and provide benefit to the project
o The computer/device must be essential for project activities and its use should
be sufficiently tracked during the life of the project
They must be allowable
o The computer/device is functioning as or in direct support of specialized
scientific equipment
o The computer is specifically identifiable to the sponsored project as an "unlike
circumstance"
They must be directly allocable
o The principal use of the computer/device must be directly allocable to the
purpose, goals, and activities of the funded projects
o If a computer/device is directly charged to a project and is used other than
incidentally for general administrative purposes, some sharing of the cost is
required.
o A computer/device may be allocated to one or more sponsored projects unless
the sponsor's terms and conditions prevent such an allocation. Such an
allocation requires that the computer/device be used primarily to conduct the
research of each project.
They must be reasonable
o There must be an informed, prudent decision regarding the cost, utility, and
value to the project
They must be non-personal in nature
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Unlike Circumstances
In some cases, however, the use of personal computers and electronic devices specifically required for
individual sponsored projects can be justified as directly benefitting those awards. In specific situations,
the purchase of personal computers and electronic devices can be an allowable direct charge to funded
projects when the conduct of the project requires a computer, e.g., the computer is attached to a piece
of equipment and is required for collection or analysis of data for the project or the computer is
specifically needed to record data while in the field, such as an archeological site. In such situations, the
computer or electronic device must be used either exclusively or primarily for the project. The use of a
computer to store non-sponsored projects information or for use outside of the lab or office where the
research is conducted (except for field work) is likely to raise the question during an audit of the
allowability on a sponsored project.
To sustain an auditable justification of the allowability of computers/devices charged directly to an
award, the computer/device must be used primarily (at least 95%) for the programmatic conduct
sponsored project. If it is 100% funded from a sponsor, the computer/device should not be used for
non-programmatic purposes on more than an incidental basis. Criteria for consideration include: (not all
encompassing, nor are all required):
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•
•
•
•
Incidental use never interferes with project use
Incidental use is solely for convenience (e.g., responding to project related e-mails in a
timely manner while away from the office)
Incidental use itself would not have justified purchase of the laptop
Incidental use never requires removing the laptop from the project location
Generally non-project files or data are not stored on the computer
The computer is never used for administrative support, such as purchasing and sponsored
project management, since these uses can never be directly charged to a sponsored
award
The PI must conform to any specific restrictions or approval requirements of the sponsor
and must assure that the computer/device would not have been purchased were it not to
support the goals of the specific research project. In addition, software and/or upgrades
purchased on sponsored awards must be necessary for the conduct of the project and
must also conform to the above requirements regardless of the computer/device on
which they are installed.
Documentation of Unlike Circumstances
In order to minimize disallowed costs through audit findings, personal computers and electronic devices
with a unit cost of less than $2,500 will not be allowed as an approved expenditure on sponsored
projects unless unlike circumstances have been documented. That is, the need has been included in the
original proposal and completely justified as to the reason it is being included, the purpose and benefit
to the project have been fully described, it has been made clear that the project will be negatively
impacted by not purchasing the computer, and it has been approved by the sponsor.
8
To provide evidence of unlike circumstances, the Principal Investigator must document in the proposal
that the use of the computer/device is beyond the normal and customary use and application of
computers/devices in the day-to-day operations of the laboratory, how the computer directly benefits
the project and how it is different from similar items provided by the department. Sponsored Programs
must approve of the sufficiency of detail in the request. The lack of documentation could call into
question the allowability of the purchase on the sponsored project. Once full documentation has been
provided to the sponsor, the University will allow the direct expense to the sponsored project
fund/index unless the sponsor has disapproved the request.
If the need for a personal computer or electronic device develops during the project and was not
requested in the original budget, the PI must provide documentation of unlike circumstances to
Sponsored Programs for review and approval. The criteria described in the paragraph immediately
above must be addressed when the request is submitted. If necessary, a new spending plan will be
prepared and forwarded to Grants Accounting.
Frequently Asked Questions
Q. What criteria may be used to determine whether a personal computer or electronic device cost is
exceptional?
A. Computer/device uses that are considered exceptional and a basis for purchase on sponsored
projects:
1. Controlling an instrument
2. Acquiring data from an instrument
3. Numerical calculations and simulations
4. Image and video analysis
5. Data analysis and manipulation
6. Data mining
7. Writing computer code
8. Data storage for the sponsored projects
9. Preparation of testing materials and recording of participant responses
Computer/device uses that are not considered exceptional:
1. Preparing proposals
2. Preparing progress reports related to the project
3. Preparing publications related to the project
4. Preparing presentations related to the project
5. Accessing library resources (journals, books, etc)
6. Administrative activities including email, internet research, budgeting, procurement, human resource
management, and effort reporting
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Questions can be directed to the Office for Sponsored Programs or Grants Accounting:
Office of Sponsored Programs
Phone: (330) 672-2070 Fax: (330) 672-7991
Grants Accounting
Phone: (330) 672-2400 Fax: (330) 672-8328
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Direct Versus Indirect Costs
There are costs associated with implementing a sponsored project that are program specific, and
general costs incurred by the university for the administration of the program. For administrative and
accounting purposes these costs are grouped into two categories - direct and indirect. Some costs,
however, are not discretely direct or indirect and may appear in either category, depending on the
circumstances.
General Criteria for the Treatment of Costs
This matrix indicates when a particular cost is normally charged directly or indirectly to sponsored
agreements. This listing provides examples of costs most commonly associated with sponsored
agreements. It is not intended to be all inclusive.
Salaries and
Wages/Fringe
Benefits
Travel
Supplies
Information &
Communication
Direct Costs
(Charged to the sponsored
agreement)
Faculty, technicians, research
associates and assistants (including
graduate research assistants and other
students performing scientfic or
technical work), postdoctoral
associates and other technical and
programmatic personnel that are
necessary to meet the goals of the
project.
Required to carry out the objectives of
the sponsored agreement
Lab and scientific supplies
Facilities & Administrative Costs
(Not charged to the sponsored
agreement)
Administrative and clerical positions, such as
secretaries, accountants, office personnel
(including student workers), purchasing
agents and buyers, administrative activities
of directors and assistant and associate
directors, executive assistants, and other
administrators.
Chemicals/Radioactive material
Custodial supplies
Glassware
Field supplies
Parts and supplies associated with repair
and maintenance of general purpose
equipment and facilities
Compressed gases and liquids
Paper
Animals
Forms
Software
Books and reference materials
Rare and precious metals and
nonprecious metals
Printing: normally indirect unless the
specific requirements of a particular
Related to administrative activities
Office supplies
Printing
project scope clearly indicates a need for
a volume of costs beyond routine.
Photocopy charges: normally indirect
unless the specific requirements of a
particular project scope clearly indicates
a need for a volume of costs beyond
routine.
Photocopy charges
Telephone long distance (project
specific)
Telephone - basic service, installation, repair,
and line charges (including ATS, WATS,
and fax)
Cellular
Repairs &
Maintenance
& Operations
Miscellaneous
Postage: normally indirect unless the
specific requirements of a particular
project scope clearly indicates a need for
a volume of costs beyond routine.
Example: mass mailing
Postage (including Federal Express, etc.)
Advertisement: recruitment of personnel
approved for a specific project, recruitment of research subjects
General advertising
Public relations
Reprints and page charges
Dues/memberships (other than those
specifically required) in business,
professional and technical organizations
Photography
Repairs and maintenance (related to
scientific and technical equipment
Subscriptions
Repairs and maintenance (facilities and
general purpose equipment)
Lease/rental of vehicles and other
equipment
Utilities
Lease/rental of off-campus facilities
Participant expenses and
student/trainee noncompensatory
support (training grants)
Insurance
Subject Payments
Fines and penalties (includes library fines)
Legal and financial services
Subawards
Equipment
Consultant's fees
Lab, scientific, and field noncapital
General purpose noncapital equipment
equipment
(includes computer and electronic devices)
Technical and scientific capital
equipment
General purpose capital equipment
Staffing the Funded Project
Overview
A guiding cost principle of sponsored project administration is that expenses charged to a sponsored
project are ". . . consistent with established institutional policies and practices applicable to the work of
the institution generally, including sponsored agreements" (OMB circular A- 21, Cost Principles for
Institutions of Higher Education). Therefore, the following requirements apply to full or partially
sponsored project funded positions:
These personnel are paid at the same level as other university employees doing similar work
and receive the same annual salary increases.
These are term positions with appointments made on no longer than an annual basis. Salary
increases are determined annually when the appointment is renewed and must be consistent
with salary increases for other university positions. Increases are never automatic for positions
funded on sponsored projects. Paperwork must be initiated to do so.
Graduate Research Assistants are paid at the same rate as research assistants in their home
department.
All appointments at any level need to be reviewed and directly approved by the Principal
Investigator overseeing the sponsored project.
Charging Personnel Time to a Sponsored Project Fund/Index
Secretarial and clerical personnel are typically not allowable direct costs as they are included in the
indirect cost rate calculation. Only when such positions have been requested and justified in the
proposal budget and approved in the sponsored project award can they be charged to a sponsored
project. An Indirect Cost Charge Exception Form should be completed at the proposal stage which
documents the unusual circumstances that justify the need for direct charging positions.
Hourly/classified staff members are paid biweekly. Time is recorded electronically using the Kronos
system. The PI should be the supervisor reviewing and approving the weekly Kronos entries for
payment. Salary and fringe benefits are charged to the sponsored project fund/index listed on the
appointing document, or for existing positions, per the Salary Distribution Revision form (see below).
Faculty, administrative and contract staff are paid semi-monthly. Salary and fringe benefits are charged
to the sponsored project fund/index listed on the appointing document, or for existing positions, per
the Salary Distribution Revision form.
Graduate Assistants are paid semi-monthly. Salary and fringe benefits are charged to the sponsored
project fund/index listed on the appointing document. Tuition is charged to the sponsored project
fund/index at the beginning of each semester unless another sponsored project fund/index is
designated.
Current employees working on a sponsored project For University staff with existing appointments
who will be spending all or a portion of their time on a sponsored project funded project (lab
technician, postdoc) a Salary Distribution Revision form must be completed (preferably at the
beginning of each project period) to allocate the appropriate percent of time to the sponsored project
fund/index and department or to other index. If an individual is supported under multiple sponsored
projects, the time is to be apportioned according to the effort committed to each.
Faculty Academic Year Support A Salary Distribution Revision form must be completed for faculty with
academic year effort on a sponsored project, to charge their time and related salary as allocated in the
project budget. This should be done at the beginning of each academic year or when the effort
changes. If the effort is identified as cost sharing the percent of effort should be charged to the cost
share index for the sponsored project.
Summer Salary Appointments Summer appointments for persons on a 9-month contract are not
automatic. An Electronic Personnel Action Form (ePAF) must be initiated on-line for these personnel
working on the sponsored project during the summer. This should be done before the end of the
preceding Spring semester. Academic Personnel releases a schedule of summer ePAF deadlines every
Spring. Contact Academic Personnel or Sponsored Programs for this list.
For sponsored project activity, faculty compensation is based on the equivalent monthly, weekly, or
even daily rate of the previous academic year salary (1/39th for each week or 1/9th for each month)
and cannot exceed the maximum allowable amount for summer (usually 13 weeks), or exceed the
maximum earnability for any time period during summer.
An ePAF should be initiated for graduate assistants receiving a full or partially-sponsored project
funded stipend and tuition for the summer. The comments section of the ePAF needs to indicate
where the tuition is to be charged, and if the student is opting in or out of PERS.
Graduate students working on a sponsored project without tuition should be paid on an hourly basis in
the summer for work on a research project.
As with all other appointment forms, sponsored project funded ePAFs must have PI approval.
Academic Personnel can initiate the required paperwork to add the PI to the approval queue, which is
a one-time process. Each Spring Sponsored Programs releases a memo, tip sheet, and calculation
spreadsheet to assist with creating summer salary ePAFs.
Hiring New Staff
University Human Resource policies and procedures must be followed when hiring personnel to work
on a sponsored project. PIs should contact their department’s Business Manager or equivalent to
inquire about hiring procedures and requirements. Standard forms, as described below, are to be used
and are generally available on-line.
New Administrative & Staff Positions (full & part-time)
Position Request Authorization (PRA) - In order to create a new position a PRA must be completed,
routed, and approved electronically by the appropriate administrators. This form establishes the
position and identifies the source(s) of funding. The form also indicates whether or not the position is
to be posted. If a waiver of posting is requested, appropriate documentation must be attached to the
PRA for review and approval by Affirmative Action. Ordinarily a Position Description Questionnaire
(PDQ) describing the responsibilities of the position must accompany the PRA. For an existing position
a PRA is necessary when the title and/or responsibilities of the position change or the position changes
to full or part-time, but a PRA is not necessary to re-appoint personnel to their existing grant-funded
position (see below for reappointing personnel).
Personnel hired via the PRA process are automatically entered into Banner – no Personnel Action Form
is required. A ‘hire completed’ email is generated by the HR system that includes the person hired,
start date/end date of the position, salary, and funding source, in addition to other information.
Sponsored Programs receives a copy of these emails for review, to verify the appointment is compliant
with the requirements of the sponsored project. When the candidate is selected this is the appointing
mechanism that places the individual in the position.
Personnel Action Form (PAF) – Sponsored project PAFs are generally only used when appointing a
short-term position (4 months or less). This is a paper form.
Reappointing personnel - When the appointment is to continue beyond the current budget period, an
ePAF can be routed for reappointment. To continue the appointment of an existing staff position that
is fully or partially sponsored project funded, a Change in Status/Term Assignment Renewal Form
needs to be completed. The form is very similar to the paper PAF but is used only for existing
appointments – the PAF is for new appointments only, of 4 months or less.
Student Employees - The hiring process for undergraduate student employees is managed by Career
Services. The online system CampusWorks! manages the recruitment and hiring process. At the time of
hiring the sponsored project fund/index to be charged is entered. To acknowledge approval, PIs should
sign a paper copy of the appointment. A copy should be sent to each Sponsored Programs and Grants
Accounting.
Consultants / Independent Contractors – IRS regulations require that any individual employed by the
University currently, or within the last year, must continue to be paid as an employee. The online
Independent Contractor Determination process will clarify how an individual is to be paid.
Participant stipends – Any perceived ‘service’ arrangement requires participants on a grant to be paid
as employees rather than via a check request. The University Tax Manager can assist in determining
whether the activity of the participant constitutes a service for the University (employment), or if the
arrangement is solely educational in nature for the participant. This determination dictates the
mechanism by which the participant will be paid.
Additional compensation - In unusual cases where consultation is across departmental lines or involves
a separate or remote operation, and the work performed is in addition to regular departmental load,
any charges for such work representing extra compensation above the base salary are allowable
provided that such arrangements are specifically provided for in the agreement or approved in writing
by the sponsoring agency.
1
Subawards
Subaward agreements are established to facilitate the collaboration of faculty and staff from multiple
institutions. These legally binding agreements are approved and signed by authorized institutional
representatives from each institution. The Vice President for Research, Kent State University’s Authorized
Institutional Official, has designated the Director of Sponsored Programs to sign subaward documents.
Kent State University may receive awards as a subrecipient partner to prime awards from other institutions, or
Kent may receive prime awards from which Kent issues subawards to subrecipient partners. In the former
situation in which we are the recipients of a subaward, the procedures for proposal preparation and award
receipt is the same as those followed for proposals submitted to and awards received from the prime funding
agencies.
A subaward relationship is one in which an individual(s) outside of the submitting organization has a separate
scope of work, is involved in the programmatic decision-making, adheres to applicable program compliance
requirements, has the right to publish results, and has the option to develop patentable technology and IP
resulting from the award.
The intent to subaward or subcontract with an investigator from a different institution is usually established at
the proposal stage. A scope of work, project budget and budget justification, indirect cost rate agreement,
institutional administrative and financial contact information, and institutional endorsement are collected at the
proposal stage for each subrecipient partner. When the proposal is funded it signifies that the funding agency
approves the arrangement. If a subaward is not anticipated in the proposal, funding agency approval generally
must be obtained by the principal investigator working through the Sponsored Programs Office.
After the prime award is received and a sponsored project fund/index is established, Sponsored Programs
personnel will initiate the process to establish a subaward agreement. A determination must be made whether
the subrecipient can administer an award in compliance with federal and agency requirements. This is
determined after the review of an audit certification and financial status questionnaire as prepared by the
subrecipient agency. When the subaward agreement is prepared the terms and conditions of the funding
agency are flowed down to the subrecipient as well as reporting requirements. Approval by the Kent PI of the
agreement is secured before the agreement is transmitted to the collaborator’s research office for review,
execution, and return to Kent. A copy of the fully executed subaward agreement will be transmitted to the PI
with instructions on reviewing and approving subaward payment procedures. Subaward agreements that
result from federal funding are recorded and reported by the Sponsored Programs Office as required by the
Federal Funding Accountability and Transparency Act (FFATA).
Periodically (monthly or quarterly) the collaborating institution will submit invoices. For cost reimburseable
agreements, this will be itemized by major cost category, for reimbursement of expenditures they have incurred
in support of the project. The PI is responsible for reviewing the invoiced expenditures to determine that the
expenses are reasonable for the progress made and tasks completed by the subrecipient before approving
payment and processing for payment with a Subaward check request. The paperwork must be signed by the
PI before being sent to Grants Accounting along with the invoice. The Grants Accounting office of the
University initiates and tracks all payments to subaward recipients.
Modifications
Modifications to the agreement are initiated upon receipt of changes to the prime award (e.g. additional funding
has been received and/or a project has been extended), or after a request from the PI for such changes (e.g.,
2
time extensions, increases/decreases in the funding amount for the subaward recipient). The PI is responsible
for notifying Sponsored Programs if a subrecipient is to receive a no-cost extension at the time of project period
extension. Subawards may be modified only to the extent allowed by the prime agreement. Modifications are
communicated to Grants Accounting.
Close Out
To ensure timely closeout of the Kent prime award, final invoices for the subaward must be received within 1560 days (as designated in executed subaward agreement) to allow for appropriate reviews, approvals and
payment. This invoice should be labeled as “Final” and processed by the PI as quickly as possible.
Cost Sharing
Federal and/or agency regulations sometimes require that the University share in the cost of a
sponsored project. The University’s contribution is called ‘cost share’ or ‘match.’ Cost sharing can be
in the form of cash or an in-kind contribution. All cost sharing must be discussed with the
departmental Chair/School Director or equivalent, before being budgeted.
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•
Mandatory cost share is cost share that is required by the funding agency. This type of cost
share is quantified in the budget and is tracked and reported in a cost share index via the
University’s accounting system. Mandatory cost share is subject to audit review.
Voluntary committed cost share is not required by the funding agency. It is still quantified in
the application for funding, requires a detailed budget, and will be tracked and reported in a
restricted index via the University’s accounting system. Voluntary committed cost share is
subject to audit review. The use of voluntary cost share is discouraged.
Voluntary uncommitted cost share is not required by the funding agency and is not quantified
in the application for funding. It will not be tracked and reported via the University’s
accounting system. Any departments/units wishing to track voluntary uncommitted cost
share can do so through their respective departmental research indexes. These can be
established by the Controller’s office if one is not currently in place.
Cash cost sharing includes any University or third party contributions of actual funds. Typical
items include faculty academic year, staff, or graduate assistant time and the associated
benefits (including tuition for graduate assistants), indirect costs including indirect costs not
claimed on the sponsor budget, or other direct sources such as cash contributed by third
parties.
In-kind cost sharing includes non-cash contributions to a project, including services and
property. These can be provided by the University or third party contributors. In kind cost
share will not be tracked through the University’s accounting system but will require
documentation on these forms - “Certification of Facilities and/or Other Items” or
“Certification of Professional Time.”
All cost shared funds must adhere to requirements in 2 CFR 215 (OMB circular A-110), and are:
•
•
•
•
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Verifiable;
Not included as contributions for any other federal project or program;
Not paid by the Federal Government under another award, except where authorized by
Federal statute to be used for cost sharing or matching;
Necessary and reasonable for proper and efficient completion of the project;
Allowable under 2 CFR 220, (A-21) Cost Principles for Institutions of Higher Education (i.e., if
charges are not allowable on grant funds they are not allowable for cost shared funds either,
per the Direct Costs and Direct versus Indirect Costs Matrix sections of the grants
management manual).
Provided for in the approved budget when required by the sponsoring agency;
Compliance Requirements for Sponsored Projects
The issue of compliance encompasses a broad range of areas that relate to sponsored projects –
from financial requirements to regulations that govern the use of human or animal subjects, as
well as requirements for hiring personnel. The Principal Investigator with guidance and oversight
by the Sponsored Programs office is the primary individual in charge of overseeing execution of
the project objectives. As such, the PI is responsible for the following:
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Confirms that the entire proposal meets the requirements outlined in the Request For
Proposals (RFP);
Oversees preparation of the technical proposal;
Identifies the budgetary requirements for the project;
Identifies required match or cost-sharing sources to comply with agency requirements;
Prepares the appropriate forms for human subject, animal subject, or Hazardous
Materials Biosafety use, if necessary.
The subject of compliance is complex and involves many diverse issues. What follows is a
summary of compliance and management issues, as excerpted from Managing Externally
Funded Programs at Colleges and Universities - A Guideline to Good Management Practices,
published by the Council on Governmental Relations (COGR) and available here.
Principle I. Compliance
The college or university has a comprehensive system in place that provides for written policies
and practices covering the scientific conduct and the administrative and financial management of
sponsored programs.
Principle II. Fiscal Administration
The college or university cost estimating, recording, accumulating, and reporting as well as its
budget administration systems are designed in accordance with generally accepted accounting
principles, the costing provisions of OMB Circular A-21, and the financial and technical terms and
conditions of the funding agency. They are designed to assure that the federal government and
other research sponsors bear their fair share of total project costs.
Areas of responsibility include:
1. Allowable Costs. The college or university has in place a financial control system that limits
costs charged to accounts funded by a sponsor to costs allowable by that sponsor, in amounts
that are properly allocable. The Direct Costs section and Direct Costs versus Indirect Costs
Matrix of the Grants Management Manual can be used to determine allowability.
2. Proposal Costing. The college or university has a proposal costing and budget administration
system which provides for consistency in preparation of proposal budgets to satisfy both internal
procedures and external regulations.
3. Financial Accounting and Reporting. The college or university has an established financial
management system that complies with federal, state, and institutional regulations and/or
policies.
4. Cash Management. The college or university has a cash management system that complies
with federal, internal, and, if necessary, state regulations and which provides adequate control
and necessary flexibility to make timely deposits and disbursements of sponsored project funds.
5. Compensation. The college or university has compensation policies that are consistently
applied to all employees and a system for documenting compensation, including supplemental
payments, into the financial management system of the institution. These systems comply with
federal requirements of OMB Circulars A-21 and A-110. The section on Staffing the Project
provides details on hiring and charging personnel to grants.
6. Cost Sharing. The college or university has policies and procedures for properly documenting
cost sharing in the same manner as costs funded by the sponsor, including mandatory and
voluntary committed faculty effort. These policies and procedures comply with federal
requirements of OMB Circulars A-21 and A-110. Details on cost-sharing are in this section of the
grants management manual.
7. Cost Accounting Standards. The college or university has appropriate systems to ensure
compliance with the cost accounting standards mandated by the federal government in OMB
Circular A-21 and has a system to update cost accounting practices as appropriate. In September
2011 a DS-II (Disclosure Statement) was filed with the University’s cognizant agency, DHHS and
is still under review. The DS-II documents in detail, the University’s cost accounting practices and
University policies that relate to management of sponsored projects.
Principle III. Procurement The college or university has a procurement system for acquiring
goods and services in a competitive, fair, and timely manner.
Principle IV. Management of Permanent Equipment The college or university has a
management system governing permanent equipment acquired from both federal and non-federal
sources.
Principle V. Human Resources The college or university has a human resources management
program including written personnel policies and procedures available to all employees that
provides safeguards to assure that the institution complies with laws and regulations regarding
recruitment, hiring, terms, conditions and termination of employment. The section on Staffing the
Project provides details on hiring and charging personnel to grants.
Principle VI. Compliance Assessments and Audits The college or university has a formal
system for compliance assessment and audit that demonstrates that the institution complies with
both internal policies and federal regulations.
Principle VII. Compliance With Protection Regulations The college or university has systems
that comply with federal and, where necessary, state and local government regulations and with
requirements of non-federal sponsors in the areas of protection of human subjects and of
animals, the environment, and in the operation of its facilities. The University’s Office of Research
Safety and Compliance oversees this function and works with Sponsored Programs to make
certain externally funded projects are compliant.
Principle VIII, Proposal and Award Management. The college or university provides
information on prospective sponsors and processes proposals in compliance with sponsor
guidelines and requirements… and has a system to manage externally funded programs in
accordance with the requirements of each sponsoring agency. The college or university has a
system to assure adequate reporting of performance of sponsored programs as well as for the
management of records and other technical data.
Principle IX. Intellectual Property The college or university has an intellectual property
management system adequate to comply with terms and conditions of its agreements with
external sponsors and institutional policies, as well as with pertinent laws and regulations
including those of the federal government. The University’s Office of Corporate Engagement and
Commercialization oversees this process and works with Sponsored Programs to make certain
externally funded projects are compliant.
Principle X. Research Integrity The college or university has a formal system, embodied in
written policies and guidance, that commits the institution and its faculty, students and research
staff to design, conduct and report their scholarly activities in accordance with accepted
standards of integrity and ethical behavior.
Principle XI. Electronic Research Administration The college or university has appropriate
procedures in place to allow it to access and utilize the electronic proposal, award, administrative
and financial management systems of the federal government or other sponsors.
Principle XII, General Research Management The college or university has a clearly defined
process for the review of research management policies and for decision making on
implementation of such policies (and) has trained personnel who are knowledgeable of sponsor
regulations, requirements and procedures.
Federal Regulations, Guidelines, and Information
Below are links for many federal regulations as well as specific agency guidelines and other
useful information for sponsored projects administration.
OMB Circulars
A-21 - (Cost Principles for Educational Institutions)
A-110 - (Uniform Administrative Requirements for Grants and Other Agreements with Institutions
of Higher Education)
A-133 - (Audits of States, Local Governments, and Non-Profit Organizations)
Federal Acquisition Regulations
Agency Guidelines
U.S. Department of Agriculture
Education Department General Administrative Regulations (EDGAR)
NEH General Grant Provisions for Organizations
NIH Grants Policy Statement
NSF Grant General Conditions (GC-1)
NSF Grant Policy Manual
NSF Proposal and Award Policies and Procedures Guide
NSF Administration of NSF Conference or Group Travel Award Grant Special Conditions
Other Federal Information
Catalog of Federal Domestic Assistance (CFDA)
Code of Federal Regulations
FirstGov
Grants.Gov
Fly America Act
Government Printing Office (GPO) Access
Interagency Edison (Invention Reporting)
Library of Congress
U.S. General Services Agency (GSA)
Domestic Per-Diem Rates
Foreign Per-Diem Rates
U.S. Government Manual
U.S. Patent and Trademark Office
Use of Human Subjects
Use of Animal Subjects
Kent State University Links
Sponsored Programs Post Award web page
Policy Register
Office of Research Safety and Compliance
Business Administrator Services (BAS) Forum
Forms Library
Monitoring Expenditures
Overview
The Banner information system provides on-line access to financial reports for each University index
including restricted indexes for sponsored projects. The purpose of these reports is to aid the PI in
monitoring budgets and expenditures.
It is the principal investigator/project director’s (PI) responsibility to review their reports at least
monthly to make sure all valid transactions are recorded, and also to make sure that any incorrect
transactions (such as keying errors) are corrected. The reconciliation of the restricted fund should be
performed in a timely manner to prevent audit issues. The monthly reports should be treated like a bank
statement for a checking account. The PI must balance the reports against records to determine what is
outstanding and to make sure there are no errors. The PI or designee should notify the Grant
Accountant if there is an error on the report.
Accessing Reports On-line
Expenditure Reports are available on-line through Flashline.
Log in to Flashline
Click on the “My Actions Items” tab at the top of the page
Scroll down on the middle column to “Finance Reports”
There are several sponsored project reports that can be accessed to monitor expenditures:
Grant Report by Principal Investigator
Grant Budget Summary
Labor Distribution
Transaction Reports
Fiscal-Year-to –Date
Monthly
Index/Fund-Org-Program Crosswalk
Grant Report by Principal Investigator
The quickest way to access the financial status of a sponsored project on a day-to-day basis is through
the Grant Report by Principal Investigator. This report reflects transactions through the previous
business day. Scroll down to select the principal investigator from the listing presented after selecting
this report, then click on “Next” at the bottom of the page and you will receive a listing of all the grants
for that individual. This listing contains the following information for each grant that investigator has.
PI name
Grant index
Status (active/inactive)
Effective Date
Type
Fund number
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Organization code and description (department)
Program code and description
Grant title
Funding agency name
Project start and end date
Click on the linked “Fund” number of the grant to receive a detailed report that is up-to-date as of the
previous business day. The resulting report summarizes expenditures by general account code. At the
top of the report the PI is listed as well as the grant accountant assigned to the project who should be
contacted if there are questions or errors. The columns contain the following information:
The Account and Title columns display the general account code description for the budget and for
expenditures.
Budget column displays the budget for that account code. This is the amount that was approved when
the proposal was funded and translated into the University’s accounting system when the spending plan
was prepared by Sponsored Programs and the grant index established by Grants Accounting.
Current Activity column displays the total current month expenditures by account code. The individual
transactions can be viewed by clicking the linked “Account” number (account code).
Project to Date Activity column summarizes the expenditures that have been charged to the index from
the very beginning of the grant through the previous business day. It includes the amounts in the
Current Activity column.
Commitments column displays encumbrances that have been made but not yet paid for. Note that the
projected amounts for salaries are only encumbered through June 30 of the current fiscal year. Amounts
budgeted beyond June 30 are not encumbered until the beginning of the next fiscal year. Also note that
fringe benefits are not encumbered, nor are indirect costs. These should be considered when
determining the actual amount remaining that is not expended or encumbered.
Available Balance column reflects the amount that is available for expenditure. The calculation is
Budget minus Project to Date Activity minus Commitments. If the balance amount is in parentheses, it is
a negative or deficit balance. Indirect costs are not encumbered but will be collected as direct costs are
charged and, therefore, not available for other expenses. The available balance should factor in any
fringe benefits and/or indirect costs that will be charged for items in the Commitments column.
Click the “Page Down” at the bottom of the page to see the next page of the report, or view and save
the report in various formats, including Excel or PDF. Instructions on saving reports are available in the
Finance Reports block in Flashline.
Other Grant Reports
The three reports that should be reviewed at least monthly are the Grant Budget Summary Report,
Monthly Transaction Report, and Labor Distribution Report. The latter two provide the detail that
supports the information on the summary report.
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Grant Budget Summary Report
This report is available in Excel or PDF format. The PDF version is preferable because you can click on the
linked information to view additional information. When you select this report you will see a screen that
requires the following:
Account Index _______
(Six-digit grant index)
Fiscal Year
_______
(Four-digit fiscal year)
Fiscal Period _______
(1-2-digit month within the fiscal year [July is 01, August-02, June-12])
When you click on “Finish” at the bottom of the page, you will next click on the hyperlink presented for
that index. The system will then start gathering up the information for the report. This may take a little
time but you can select the option to have it delivered to you via email.
The resulting report summarizes expenditures by account code within general budget categories such as
Salaries & Wages, Employee Benefits, etc. At the top of the report the PI is listed as well as the grant
accountant assigned to the project who should be contacted if there are questions or errors. The
columns displayed are as described above under ‘Grant Report by Principal Investigator.’
Final month-end reports are available the fifth working day of the succeeding month but current reports
can be accessed daily.
The PI can quickly review the “Available Balance” column along the right side of the report to ensure
that grant expenditures are in line with the budget. Balance amounts surrounded by parentheses
indicate over-expenditure of that category. At the end of the report is a summary line for the entire
grant period. A review of the “Current Activity” column in the middle of the page indicates expenditures
incurred in the current month by cost category.
Transaction Report – Monthly
When this report is selected a screen will require the following:
Account Index _______
(Six-digit grant index)
Fiscal Year
_______
(Four-digit fiscal year)
Fiscal Period _______
(1-2-digit month within the fiscal year [July is 01, August-02, June-12])
On the next screen, click on the highlighted “Account” index for the Transaction History List Report. This
report lists every transaction made during the month except for salaries and benefits which are on the
“Labor Distribution Report” (see below).
The transactions are in the same order as on the budget summary with subtotals. The document
number assists the grant accountant in tracking the transaction if necessary. Clicking the highlighted
codes in the Rule Class column drills down for more detail on that particular transaction. There are
several pages for each month so be certain to review all pages by clicking on Next Page at the bottom of
the screen. When an error is detected or if you need further information about a transaction contact the
grant accountant assigned to your grant.
Labor Distribution Report
When this report is selected a screen will require the following:
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Account Index _______
Fiscal Year
_______
Fiscal Period _______
(Six-digit grant index)
(Four-digit fiscal year)
(1-2-digit month within the fiscal year [July = 01, August= 02, June=12])
On the next screen, click on the highlighted “Account” index to access the Labor Distribution Report.
This report details the individuals employed by the University who have been paid with grant funds. It
also details the fringe benefits for those individuals. The report displays the encumbrance (the amount
allocated for that individual in the current fiscal year), the amount paid in the current month, and the
total expended year-to-date. If an unfamiliar name is listed, or someone is not listed who should be at
the level of effort on the grant, double-check any personnel paperwork that was submitted. If that does
not resolve the issue contact the grants accountant assigned to this project.
From this screen you can click on the account code number and title and see when and how much all of
the individuals paid from that account code were paid for the fiscal year. From the Labor Distribution
Report page you can also click any individual and receive a report of when and how much that person
was paid.
Transaction Report – Fiscal-Year-To-Date
There may be an occasion when the PI or project staff wants to review all transactions that have
occurred during the fiscal year to a specific vendor. This report is accessed the same way as the monthly
transaction report and has the same drill down features.
Position Control Report
This report is available and lists the positions assigned to an index. It may prove to be useful for large
funded projects that fund many personnel positions.
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Kent State University Controller’s Office Instructions on running the new Flashline Finance Reports Includes the Budget Summary, Labor Distribution, Monthly and Year‐to‐Date Transaction reports *Please note: These instructions only apply to the NEW Flashline reports. Flashline Finance Reports Location: ▪ The Flashline reports can be located by logging in to Flashline and selecting the “My Action Items” tab. The Finance Reports are located in the middle section of the page. Running the Flashline Reports: ▪ Select the report in which you wish to run by clicking on the report name. Prompt Page: ▪ This will bring up a prompt page. Follow the directions on the prompt page to enter the information needed. ▪Once the information has been entered on the prompt page, click the FINISH button at the bottom of the page. Index Page: ▪ When you click FINISH, this will bring up a page listing the departmental index previously entered on the prompt page with the corresponding Fund, Organization, and Program code information. ▪ Additionally, this page will provide any changes associated with the Fund, Organization, and Program for that index by effective date. ▪ Select the index with the appropriate Fund, Organization, and Program code combination in which you wish to retrieve financial data. ▪ This index listing is available if you wish to retrieve financial reports on old fund, org., and program combinations made mid‐fiscal year. *Please note: changes in descriptions are also included in the listing. As a result, in a description change, please select the most recent effective date. See the following example………………. In this example, index 100304 had a change in index description. The most recent effective date was selected by clicking on the first index combination listed. Output Report: ▪ When you click on the index from the index page in which you wish to retrieve financial data, an output report is produced. ▪ The new reports are formatted to include drill through functionality. Drill through functionality is available where a report field is underlined and in blue text. Click on the field to drill down to more detailed information. Report Download Instructions: ▪ When an output report is produced, you have the ability to select a download format. drop down arrow. There are four options to select from when Selecting a download format: Click on the icon choosing a report format; HTML, PDF, XML, EXCEL. 1) The report output is currently in HTML format; therefore, by selecting HTML there will be no change to the report format. 2) By selecting view in PDF format, the report output is formatted to PDF. The drill through functionality of the reports is still available when selecting PDF format. 3) By selecting XML, the report is formatted in code and not a readable report format. XML was designed to hold or carry data, not to display data. For the most part, this option will not be beneficial when attempting to view and read your monthly financial reports. 4) By selecting view in Excel, there are five options to select from; Excel 2007, Excel 2002, Excel 2000 Single Sheet Format, Excel 2000, and CSV format. When selecting any of the Excel options, the drill through functionality of the reports is disabled. Note: When using the drill through functionality of the finance reports, you can select a new report format at any point when drilling through the data. Just remember, when selecting an Excel format, all drill through functionality is disabled. Returning to the prompt page: ▪ When viewing an output report, simply close the current window until you return to the index page. ▪ To get back to the prompt page from the index page, select the run bottom (
page. ) in the top, right hand corner of the