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2009-10 AUDIT AND UNC FIT STANDARDS FOR SPONSORED PROJECTS
DEPARTMENTAL KEY PERFORMANCE INDICATORS (KPI)
Reportable Conditions and/or Disallowed Costs

These standards are provided as general University requirements and best practices for management of sponsored projects. Specific awards/sponsors may have more restrictive requirements and timeline guidelines. Specific transactions may have more restrictive StatelUniversity requirements and timelines for processing.

Both the Principal Investigator (PI) and the Departmental Administration (DA) share duties/responsibilities to assure compliance with all grant terms/conditions and the University KPIs. The distribution of specific duties/tasks to individuals will vary by department.

Departmental compliance with these standards is subject to review by UNC-GA under the UNC FIT (Finance and Information Transformation) initiative and by internal and external auditors.

HRJPAYROLL PRACTICES AND EFFORT REPORTING

PCF/EPAF PROCESSING

BEST PRACTICE - Before work start date.
STANDARD - Within 30 days of start date.
MAXIMUM - Within 90 days of start date.
ACTION - PCFIEPAF will be denied if> 90 days of start date or less than 2 weeks before ERS closing due date (charge to grant will not be allowed).

SALARY REDISTRIBUTION

BEST PRACTICE - Within 30 days of pay period.
STANDARD - Within 60 days of pay period.
MAXIMUM - Within 90 days of pay period (applied in system; consider processing time 80 days to assure timeliness).
ACTION- Transfers> 90 days will be denied (charge to grant will not be allowed).

EFFORT CERTIFICATION (ERS) - Applies to both paid and cost shared effort.

STANDARD/MAXIMUM - Within 45 days of certificates distributed.
ACTION - Costs disallowed if certification not processed on timely basis. Costs will be transferred to a non-sponsored fund and cannot be moved to a sponsored project.

DEPARTMENTAL EFFORT REVIEW SYSTEM - Applies to both paid and cost shared effort.

STANDARD - Department maintains master of effort commitments and monitors all effort reporting requirements for compliance and timeliness.

  • Upon receipt of awards - Paid commitments noted, master maintained.
  • Upon receipt of awards - EPAFs reviewed for action needed for paid commitments. PCFs/EPAFs processed, as needed.
  • Upon receipt of awards - Cost share efforts noted on master for ERS periods.
  • Upon receipt of awards - PI notified to contact Departmental Administrator for
  • changes, additions, deletions throughout the life of the award (30 days best practice).
  • Adjustments made on a timely basis, as needed.
  • For federal awards, for PIs and Key Personnel - minimum 75% requirement
  • monitored. Contact OGC for additional action if 75% cannot or will not be met.
  • Monitor faculty cost share effort commitments - maximum 20% cumulative, all
  • awards. At 25% normally a buyout (charge to grant), not cost share, should be
  • processed. Cost share 25% or more must be preapproved by VC.
  • Monitor PI must show some level of effort, paid or cost share, for all awards
  • (minimum 1-5%).
  • Monitor PI/Co-PI may not be paid 100% from sponsored projects (minimum 5% must
  • be from non-sponsored funds).
  • For federal awards - no clerical/secretarial/administrative salaries without A21
  • exception approval on file with OGC.
  • ERS Pre-Review-
    • * Review queue. Notify ERS if any individuals should not be in your queue. Standard 2 weeks.
    • * Review queue. Notify ERS if any individuals, not showing, need to have certification for cost share, etc. Standard 2 weeks.
    • * Review queue... for cross-departmental individuals, coordinate with other department prior to certification.
    • * Review ERS distributions with PIs and certifying individuals for accuracy and completeness (includes cost share). Make necessary adjustments prior to certification.
    • * PIs should review/verify all individuals paid on their awards. In most cases, this will be off-line review/approval so that paid individual can certify their own effort report.
    • * Verify review/certification system set up.
    • * Faculty and Post Docs must certify their own effort.
    • * All employees normally must certify their own effort. Contact OGC for allowable exceptions under certain circumstances for students/staffthe PI or immediate supervisor may certify on an exception basis.
    • * Pre-Reviewer and Certifier may not be the same individttal.

ACTION - Cost may be disallowed if appropriate standards for effort review and processing are not documented and processed by the department on a timely basis.

PAYROLL DISTRIBUTIONS - Accuracy, appropriateness, allowable, completed corrections. Review each fund for - correct amounts, correct individuals (named individual is working on project) and missing individuals. Verification process should be documented.

BEST PRACTICE - 30 days - Monthly review of payroll summaries.
MINIMUM - 60 days
MAXIMUM - 90 days ...correction must be processed within 90 days and must be processed prior to ERS certification; whichever is first.
ACTION - Costs will be disallowed - cannot be charged to sponsored project.

NON-SALARY EXPENDITURES

REIMBURSEMENTS (INCLUDES TRAVEL VOUCHERS)

BEST PRACTICE - 30 days
STANDARD - 60 days
MAXIMUM - 90 days or prior to final FSR/Invoice; whichever is first.
ACTION - Costs will be disallowed - cannot be charged to sponsored project.

DIRECT PAYS or PORT (INCLUDES SUBCONTRACTOR PAYMENTS)

BEST PRACTICE - 30 days from cost incurred or invoice received.
STANDARD - < 60 days
MAXIMUM - 90 days or prior to final FSR/Invoice; whichever is first.
ACTION - Costs will be disallowed - cannot be charged to sponsored project.

EXPENDITURE DISTRIBUTIONS (REVIEW ACCOUNTING LEDGERS) - Accuracy, appropriateness, allowable, completed corrections. Review each fund for - correct amounts/allocation, related to project activities, necessary for completion of project. PI approval and verification process should be documented.

BEST PRACTICE - Review/approval prior to cost incurred. Review ofaccuracy on ledger 30 days.
STANDARD - 60 days
MAXIMUM - to process corrections - 90 days or prior to final FSR/Invoice; whichever is first.
ACTION - Costs will be disallowed - cannot be charged to sponsored project.

ALLOWABLE COSTS - FEDERAL AWARDS - All EXCEPTION APPROVALS
No A21 unallowable costs without A21 exception approval on file with OGC.

BEST PRACTICE - Approval prior to incurring cost or within 30 days of cost incurred.
STANDARD - Approval 60 days of cost incurred.
MAXIMUM - Approval 90 days of cost incurred or prior to [mal FSR/Invoice; whichever is first. 30 days from OGC notification of discovery or prior to final FSR/Invoice; whichever is first.
ACTION - Costs will be disallowed - cannot be charged to sponsored project.

GENERAL FINANCIAL MANAGEMENT REVIEWS

EXPENDITURE RATES/PROJECTED EXPENDITURES (budget balances)

BEST PRACTICE - Monthly/quarterly.
STANDARD - at 6 months/50% of budget period. (<25% reportable)
MAXIMUM - at 9 months/75% of budget period. «50% reportable)

EXPENDITURES IN LAST QUARTER OF BUDGET PERIOD

BEST PRACTICE - All necessary expenditures booked and all necessary corrections processed prior to budget end date.
STANDARD - No equipment or large expenditures in last 60 days. No expenditures for the purpose of reducing budget balance - must be necessary to complete the goals of the project. All goods must be received and used prior to the end date of the award. No stockpiling.
MAXIMUM - No equipment in last 30 days. No large expenditures in last 30 days. All goods must be received and projected to be used prior to the end date of the award. No stockpiling for future use. Specific exceptions may apply for equipment-only or specialized projects - contact OGC for clarification/exception. No expenditures for the purpose of reducing budget balance must be necessary to complete the goals of the project.

COST SHARE PROPOSED - All cost share must be documented in the accounting and effort reporting system or it cannot be reported to the sponsor to meet the cost share/match requirements. Cost share is subject to the same audit standards as costs charged directly to a sponsored project. State and University policies require that all cost share be minimized.

BEST PRACTICE - Do not propose cost share.
STANDARD - Cost share should be limited to projects where the sponsor has a mandatory cost share/match requirement or where the PVChair/Dean have determined there are benefits to the University and it is essential for the project.

MAXIMUM- Effort cost share should be limited to 20% cumulative, from all awards. Effort cost share of 25% or more (cumulative, from all awards), must have the prior approval of the appropriate Vice Chancellor.
All non-salary cost share must have the prior approval ofthe appropriate Vice Chancellor.

COST SHARE REPORTING/MONITORING/DOCUMENTATION

BEST PRACTICE - Cost share should be reviewed/documented monthly in conjunction with expenditures charged directly to the sponsored project.
STANDARD - Quarterly for non-salary, ERS for salary/effort.
MAXIMUM - Every 6 months a cost share reconciliation must be filed with OGC. A final cost share reconciliation must be submitted to OGC prior to the final FSR/Invoice.

AWARD CLOSEOUT - OGC sends the PI/DA a pre-term notification when awards are near their end date. If not already started, a complete review ofthe status ofthe award should be undertaken at the time of notification. Including, but not limited to:

  • Contact OSP if a no-cost-extension is needed.
    Standard - Extension requests must be processed prior to the budget end date.
  • Contact OGC if a rebudgeting request is needed.
    Standard - All rebudgeting requests must be approved prior to the budget end date.
  • Review planned/projected expenditures and adjust, as needed, prior to the budget end date.
    Standard - All costs must be incurred prior to the budget end date.
  • Review all expenditures for accuracy and allowable costs and correct, as needed, prior to the budget end date.
    Standard - All corrections must be processed within timeliness standards and prior to the final FSR/Invoice.
  • Terminate/adjust all EPAFs, as needed, prior to the budget end date.
    Standard - All adjustments must be processed within timeliness standards.
  • Review progress/technical or other reporting requirements.
    Standard - All necessary reports must be submitted to the sponsor by the due date.

BANNER FUND CLOSEOUT - Zero fund balance, activity ended.

BEST PRACTICE - All necessary expenditure corrections completed within 30 days of budget end or before final FSRlInvoice; whichever is first. All EPAFs and standing orders corrected prior to or within 30 days of budget end date.
STANDARD - Deficits or residuals cleared within 60 days of budget end date.
MAXIMUM - Deficits or residuals cleared within 90 days of budget end date.
ACTION - Deficits/residuals not cleared within 90 days ofbudget end date may be unilaterally transferred by OGC. Costs cannot be transferred to another sponsored project.