Processing an Award - Expenditures - Allowable, Allocable & Appropriate - & Audit Implications

The PI has authority to sign for all expenditures related to the award. In some cases, the University requires additional authorization. The PI may delegate signature authority to another individual at the University, such as a department financial officer or business manager, however, he or she retains final responsibility for financial integrity of the program.

Signature Authorization

The PI or an employee to whom the PI has designated signature authorization must provide written approval of all expenditures of sponsored project funds. Specific dollar amounts determines the appropriate expenditure authorization.

For Main Campus sponsored project centers beginning with 2x, 3x, or 4x, RAS will send a green signature authorization card to the PI at the time the award notification is sent. The PI signs the card and returns it to RAS. This authorization allows expenditures up to the full amount of the award. Additional authorization needed on certain items, such as personnel forms, will be discussed below in the appropriate sections.

Main Campus centers beginning with "55" are subject to the Expenditure Authorization Policy ( XXX ). The University Signature Authorization card (white) will be sent with the award notification. These cards require the PI's signature as well as that of his or her immediate supervisor.

Post-Award Administrative Activities

The PI, or his or her designee, must submit all requests for expenditures to SP/RAS for approval. SP/RAS reviews all requests to make sure they meet both the terms of the award and University policies; consistent application of current University policy and procedures is required on external awards. All University forms currently available for such expenditures (e.g., salaries and wages, travel, supplies and equipment, check requests, and hiring of personnel) must be properly completed before awarded funds can be utilized. Forms and instructions are available in the appropriate Deans' Offices and/or departments. Commonly used Budget Categories are listed in the Chart of Accounts.

Charges to grants and contracts for materials received and services rendered can only be made prior to the expiration date of the award. Investigators should refer to the appropriate section of the manual or contact SP with any questions regarding processing procedures. Expenses should be appropriate and reasonable with regards to the project as outlined in RAS Policy and Procedure., and OMB Circular A-21


When an investigator requests a budget revision, prior to the expenditure of funds, Grants Management must approve the request and justification. The request may be approved if sufficient funds remain in the award and if the funding agency grants the Grants Management division approval authority. If approval from the funding agency is necessary, the PI must justify in writing the request to the funding agency; the Grants Management division must countersign this written request. In such cases, re-budgeting is not permitted unless the request has been approved in writing.

Prior Approvals

Changes in other aspects of sponsored projects may require prior approval from either the Grants Management division or the funding agency. In all cases, the PI should contact the Grants Management division first. The following lists some of the most common changes to federally funded projects that will require prior approval:

  • change in the scope of the research objectives;
  • change of principal investigator;
  • change in the grantee organization;
  • need for additional funds;
  • deviations from special conditions of the grant;
  • incurring or committing pre-award costs prior to the official start of the grant or contract, and
  • incurring expenditures after the official termination of the project period.

The University generally seeks approval from federal funding agencies for any changes in the scope of work, changes in key personnel, and requests for additional funds.

On most federal grants, the Grants Management division has the authority to approve transfer of funds between budget categories (including pre-award costs up to 90 days in advance of the start date), no-cost extensions of up to one year, and the carrying forward of unobligated balances from one funding period to the next.

Carry-Over of Funds

Some agencies allow carry-over of funds from one budget period to the next. However, the PI must justify and document carry-overs in excess of 25% of the total direct cost. The justification must be on file in Grants Management. Because federal agencies are currently scrutinizing carry-over of funds very closely, they may not allow carry-overs in excess of 25%, or they might deduct the carry-over from future funds.

Change In Project Director

Notify the Grants Management division whenever there is to be a significant change in the level of participation by the project director or PI for a continuing period of three months or when an individual withdraws from the project entirely. The PI is to notify the Grants Management division no later than thirty days before the expected date of departure or change in participation level. If the PI withdraws, the Grants Management division will work with the Department Chair or Dean to attempt to identify an individual acceptable to the funding agency to continue the project. The Grants Management division will also notify the awarding agency of proposed alternative plans. If such arrangements are not acceptable to either the Grants Management division or the funding agency, the project may be terminated.

Program Income

One further requirement of recipients of awards is the treatment and reporting of Program Income. Program Income may be defined as gross income earned by a recipient of an award from activities part or all of which are borne as a direct cost by the award or counted as a direct cost toward meeting a cost sharing or matching requirement. Program Income may include: fees from services performed during the award period; proceeds from sale of real property, equipment, or supplies; usage or rental fees; patent or copyright royalties; and third-party reimbursement for hospital or medical services. Agencies providing awards require that information on Program Income be included in applications submitted for awards; they also require reporting of Program Income during the award period. Certain agencies, such as the National Science Foundation (NSF), the Public Health Service (PHS) and the Department of Education, have printed regulations dealing with the treatment of Program Income. In most instances, the award document indicates what the recipients' responsibilities are regarding the reporting of Program Income. Any questions on treatment and reporting of Program Income should be directed to Grants Management/RAS.

Considerations Not Involving Project Support

A PI who requests special arrangements, such as the establishment of course credit, tuition remission, a new academic program, or assignment of space, should forward the request to the Dean and/or other appropriate University officials for approval.

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