After the acceptance of an award, the Office of Contracts and Grants (OCG) will work with Financial Accounting to establish a restricted account for the project.
The OCG will work with Financial Accounting on establishing an index for new awards. Once all required information is received and all compliance issues are satisfied the OCG will email the project director and administrative support an email containing procedure information. This email will include the account index, project period, and budget information for the specific project. The procedure information highlights university policies and procedures that are important to grant management. However, the procedure information may not contain all the information necessary for proper award management and it is the responsibility of the project director and administrative staff to be aware of all university policies and specific grant terms in order to properly manage the award.
After the procedures email is received the account is then ready for expenses to be charged.
Additional information will be coming soon.
Under Construction
The Federal Office of Management and Budget (OMB) Circulars apply only to federal and federal pass through awards. The federal guidelines do not apply to awards from non-federal sources. However it is always wise to question if the expense is allocable, allowable, and reasonable, regardless of the funding source. OMB leads in the development of government-wide policy to assure that grants are managed properly and that Federal dollars are spent in accordance with applicable laws and regulations. OMB does not award grants. In order to receive federal funds an institution must ensure that it can comply with the proper oversight of Federal funds. ISU falls into the area of “Education and Non Profit Institutions” and we are subject to only the three Circulars listed below:
Cost Principals for Educational Institutions
Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations.
Audits of States, Local Governments, and Non-Profit Organizations
Federal regulations in 2 CFR 200.213 related to Suspension & Debarment must be adhered to by Indiana State University for federally funded external grant awards. This requirement applies to purchases/contracts greater than or equal to $25,000. Contracts of this size must include Purchasing in the suspension/debarment review and verification process of the vendor in conjunction with the signature process for the contract. Purchasing involvement ensures that proper documentation is retained in University records to show that suspension/debarment was verified for the contract in the event of a future audit.
In addition, subagreements with subrecipients on federal awards greater than or equal to $25,000 must address Suspension & Debarment during the development and signature process for the subagreement. The Office of Sponsored Programs provides assistance in ensuring this federal requirement is met when preparing subagreements for federal subrecipients. This information is retained in University records for reference in the event of a future audit.
The Departmental Reporting System has been developed to allow departments to run their own monthly financial reports. The preferred method of Departmental Reporting is the web-based “Finance Self-Service.” In order to access the Finance Self-Service please email Barb Tschida. Further information can be found on this on Financial Accounting’s website.
The OCG will often email financial reports to departments as a project is ending or close to the time a financial report is due to an agency. Departmental can also request a financial report from the Office of Contracts and Grants, however, the development of the report by OCG will delay the PI’s access to the information. It is much quicker to use Finance Self-Service as noted above.
Reconciling Guidelines
Under Construction
Each agency has its own guidelines of what may be considered allowable and unallowable. Each award should be carefully reviewed to identify these limitations. ISU also has policies for allowable and unallowable costs. Even though an agency may allow a cost, ISU’s policy may not and the stricter policy must be followed when determining what is allowable and unallowable.
For federal and federal pass through accounts the government has given guidance as to the type of cost allowed or not allowed. Federal OMB Circular A-21 give specific guidance on items of cost. In order for a cost to be allowed as a direct expense it must be:
Allocable – Used solely to advance the project work can be indentified specifically with a particular project or activity.
Allowable – Within the agency guidelines allowable per OMB Circular A-21 and allowable under ISU policy.
Reasonable – Necessary, can be justified for the project and is consistent with other established policies and practices
Most of the items stated in Circular A-21 as unallowable direct costs are such because that classification of cost has been included in the indirect cost rate determination. You cannot classify one type of cost as both a direct cost and an indirect cost as that would be double charging the government. If a cost is included in the Facilities and Administrative (F&A) ) rate determination (indirect costs) it cannot be also booked as a direct expense to an account