Grant (Contract) AdministrationThis page is intended to show SCSU faculty how awarded grants are properly administered.
Post-Award Guidelines for Grants and Contracts
SPAR is the department that, together with university accounting, is charged with ensuring that all provisions of all Grant awards and 2 CFR Chapter I, Chapter II, Part 200, et al., Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards is followed at SCSU. It is responsible for ensuring that all other requirements of the grant contract are observed as required by granting agencies and that files are properly maintained and retained so as to pass an auditor's review. Non-Government agencies may or may not specifically require observing these Federal regulations, but in order to ensure that all SCSU processes and policies are able to pass annual audits, all grants procedures at SCSU follow these government requirements.
The following pages will explain how grant budgets are posted and expenses are applied against the budget, how funds are received from the granters, and who develops and submits financial and program progress reports.
1. Awards: If you receive an award letter indicating that your grant has been funded, congratulations are in order.
Award letters are usually sent to the project director, the president of the university and/or SPAR. SPAR must receive and maintain award letters for the auditable files as documentation that the grant is funded. Therefore, upon receipt of an award letter, please insure that SPAR receives the award letter. Some funding sources require a fully executed contract, agreement, or memorandum of agreement with SCSU. In order to be a legal and binding contract with SCSU, contracts and agreements must carry the signatures of both parties. Government agencies will send a grant award notification. Private organizations, state, and local entities often send a contract or memorandum of agreement with a letter notifying the project director of the award. This will need to be signed by the university and the agency. After all signatures are in place, or the contract is fully executed, the grant is then approved.
Please note: In accordance with the BOR Resolution dated January 19, 2012, only the president, vice presidents, and chief officers are authorized to sign contract agreements on behalf of the university. Violation of BOR policy may result in personal liability.
When a contract or agreement is required, the project director must forward the document to SPAR for review. There are mandatory clauses that the legislature requires be included in all contracts. SPAR will work with your funder to include the necessary clauses and obtain the appropriate approvals from the University and the Attorney General’s Office. SPAR will then forward the approved document to the funding agency. Once the fully executed contract or agreement has been received in SPAR, SPAR will prepare a Banner Org. Create Form and a Grant Administration Data Sheet (GADS) which will authorize the opening of an org. number and the loading of a budget into that Org. At that point, you may begin to hire and spend in accordance with university policies.
SPAR will notify the president, Academic Affairs, Institutional Advancement, Public Affairs, Faculty Development, appropriate dean, and appropriate chairman when a grant is funded. If your funder is a private foundation or corporation, SPAR will provide Institutional Advancement with all of the required information.
2. Contract Types:
There are two major types of contracts (grants): fixed-price contracts and cost reimbursement contracts.
A fixed-price contract exists when the contractor (SCSU) receives an agreement that clearly defines the requirements of the task and has a set price for completing this task. Payment is tied to completion of items under the statement of work or delivery of goods, rather than level of time and materials expended. Whether the university expends more or less money than the fixed-price contract is irrelevant to the funding agency whose payment remains the same. The university remains responsible for completion of the project or deliverable, regardless of whether or not funds are exhausted. A fixed-price contract is usually used when there are definite specifications for the goods or services being performed and when reasonable and fair prices can be established at the outset of the contract with a minimum of risk.
A cost reimbursement contract occurs when the contractor (SCSU) is reimbursed only for actual costs incurred in the performance of the statement of work. A cost reimbursement contract establishes a ceiling on the amount of the contract. The contractor will be reimbursed only for all allowable costs incurred and may stop work short of completion in the event that agency funds are exhausted.
All encumbrances for cost reimbursement grants must be submitted prior to the end date of the grant. All invoices for cost reimbursement grants must be paid no later than 30 days after the grant end date for services rendered during the grant period. Cost reimbursement grants usually require the submission of a final expenditure report after the project period. Any revenue remaining in the grant will be returned to the agency (See section on Reports).
All expenditures for fixed-price contracts for services rendered during the grant period must be submitted for processing no later than 90 days after the grant end date. Fixed-price contracts may require a final expenditure report; however, any balance remaining after this date will become the property of the university.
SPAR will indicate on the GADS whether your grant is a firm fixed-price contract or
a cost reimbursement contract based on the terms and conditions in your contract.
3. The Budget & Revisions:
The GADS will establish your initial budget based upon the budget specified in the award document.
All expenditures including, but not limited to, personnel appointments, timesheets, P-Card charges, purchase orders and travel must be approved by SPAR in advance of incurring the obligation.
Your funder will have rules for when and how you may change your budget by moving money between line items. Most Federal Grants will allow you to move some money between line items without contracting officer authority. Each agency has differing policies. SPAR will explain your revision rules to you when your contract is executed.
Due to the amount of time required for budget revisions, a maximum of one budget revision per quarter is allowed without the approval of the vice president for Finance and Administration. It is important that project directors plan accordingly. Grant expenditures based on a budget revision will not be processed until the necessary approvals have been received and the Banner budget has been revised.
Budget change requests will not be approved if they move substantial funds from equipment, scholarships, G.A. and/or student labor line items to salary for the P.I. and other faculty without approval from the appropriate Dean.
For a revision that does not require contractual authority, the P.I shall notify SPAR of the requested line item revisions. The Post Award Administrator will discuss the requested changes with the P.I. to ensure that the project can be completed with the revisions requested. Upon reaching agreement on the revisions, the Post award administrator will prepare a revised GADS showing the funds to be moved in and out of each category. The revised GADS will be reviewed by the PI to ensure accuracy before being sent to the Grants Accountant who will revise the budget in BANNER.
For a revision that does require contractual authority, the P.I shall notify SPAR, in writing of the requested line item revisions. After SPAR reviews the budget change request against agency guidelines to ensure compliance, either SPAR or the PI shall request the budget modification from the funding agency. Upon receipt of written authorization, SPAR shall obtain necessary signatures to execute any required documentation after reviewing it with the P.I. to ensure accuracy. The Post award administrator will prepare a revised GADS showing the funds to be moved in and out of each category. The revised GADS will be reviewed by the PI to ensure accuracy before being sent to the Grants Accountant who will revise the budget in BANNER.
In the event that a request for a budget revision is denied, SPAR will work with the P.I. and their Dean to find other support for needed funds.
The University Accounting Office will maintain the posting of expenses against the Banner budget so as to maintain accurate financial records. SPAR will maintain a spreadsheet of expenditures authorized by SPAR. SPAR will reconcile the spreadsheet against BANNER on a monthly basis to monitor the spend rate on the project and to ensure that all authorized charges have been captured in BANNER and that no unauthorized charges have been charged to the grant account.
These monthly reviews are also intended to monitor the progress and spend rate on the grant. Should it look as though a potential overrun may occur, SPAR will work with the PI to contact the funding agency to determine whether additional funds or a change in the statement of work can be obtained. Should Agency relief be denied, and overrun occurs or will occur, SPAR will work with the Dean, PI, comptroller and Provosts office to determine what unrestricted account can absorb the unallowable costs.
Accounting will file financial reports to the granting agencies as required by the reporting schedule of the agreement and summarized on the GADS. Accounting will provide additional accounting reports to the PI when requested.
The University Accounting Office is also responsible for carrying over any unspent funds into the next FY when authorized by the grantor.
The PI is responsible for carrying out the technical aspects of the grant as well as maintaining their own accurate financial records of all expenses charged against the grant's budget so that they can participate in budget review meetings.
SPAR assists grantee in understanding the budgetary implications of decisions made on grants spending. SPAR also helps oversee expenditures, insuring that they conform to the intentions of the granting agency, the approved budget, and the allowance of costs in accordance with federal regulations.
4. Personnel: Current Policies and forms for the authorization of payroll for university positions may be found on the Human Resources website at:http://www.southernct.edu/faculty-staff/hr/forms.html
Appointments of a person into a permanent/part-time position require establishing the position (Personnel Change Request Form). Following the approval of the PCRF, a personnel action form is required to complete the hiring of the selected individual. All personnel forms may also be found on Internal Forms page of the SPAR Website: http://www.southernct.edu/faculty-staff/spar/grant-administration/grant-forms.html
After receiving approvals from the department vice president and the president, the person will receive a letter from the president making the appointment. The person may not start working until they have received the president's notification letter and they have accepted the appointment by signing and returning the letter.
Rosters for Lecturers, University Assistants, and Graduate Assistants may be generated and presented to department head and dean. SPAR will review rosters to ensure that the grant supports both the funding and purpose of this position. SPAR will obtain approvals from the applicable vice president (Academic Affairs/Student Services) and then forward the roster to Human Resources. After HR approves the position, the roster is forwarded to the vice president of finance. This will be the final approval before the new employee is notified. They will then be notified by a letter from Human Resources. They must sign and return this letter to Human Resources before starting to work.
SCSU secretaries, who are to be paid to work on a grant in addition to their regular position, must perform work during overtime. An overtime time record form needs to be completed for all overtime work done by secretaries. This record must be forwarded to SPAR for approval to ensure that the overtime charges will be applied to the grant and so the secretaries may be paid.
In accordance with the policies of the Office of Management and Budgets, all personnel working on externally funded programs must complete a time and effort report which certifies after the fact the hours that have been worked and that the work that has been performed has been in furtherance of the statement of work of the activity charged.
To ensure that SCSU is in full compliance with the 2 CFR Chapter I, Chapter II, Part 200, et al. Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards; Final Rule, this time and effort reporting shall be completed as follows:
- For or other salaried employees Faculty performing work under release time or as all or part of their regular salary, the Time and Effort Activity report shall be filed monthly and certified by the Project Director/Principal Investigator or Supervisor if the person filling out the report is the Principal Investigator or Project Director. The Report will then be forwarded to SPAR for Retention. In the event that the time spent is not compensated by the grant, but rather counted as match for the grant by the university, the In-Kind Time and Effort Report shall be used.
- For Faculty performing work under any part time hourly or credit provision of the AAUP contract, the Instructional Faculty Time Sheet for Grant Compensation for Non-Bargaining Unit Work Authorization shall be completed monthly and certified by the Project Director/Principal Investigator or Supervisor if the person filling out the report is the Principal Investigator or Project Director. The Report will then be forwarded to SPAR for Retention.
- For Administrative Faculty performing work under 16.5 time, the Administrative Faculty Time Sheet for Compensation Authorization for Contract Grant Activities (16.5) shall be completed monthly and certified by the Project Director/Principal Investigator or Supervisor if the person filling out the report is the Principal Investigator or Project Director. The Report will then be forwarded to SPAR for Retention.
- For University Assistants performing work under grants and Contracts, a separate work University Assistant Appointment Form for each grant or contract must be submitted. In addition, each biweekly pay period, the UA must fill out a separate time sheet for each project that they are appointed to. Commencing Summer Semester 2014, these timesheets will contain the following certification above the supervisor’s signature:
- “SUPERVISORS CERTIFICATION: I certify that services have been performed in a satisfactory manner and in accordance with University regulations during the period covered that this report is current in all details. If this University Assistant is grant funded, I further certify that all of the time reflected was spent on tasks in furtherance of the Grant Statement of work, BANNER ORG #__________________ and Grant Name____________________________________________.”
- The supervisor shall manually enter the Title and the BANNER Org. of the project on each timesheet to ensure that all work charged to the correct project. It is the supervisor’s responsibility to verify that all of the time noted on the timesheet was spent in furtherance of the statement of work of the Project title and BANNER Org. number noted on the time sheet. Timesheets for individual UAs will be provided each semester by Payroll.
- For Student Workers performing work under grants and Contracts, a separate Student Employment Work Authorization Form for each grant or contract must be submitted. In addition, each biweekly pay period, the Student Worker must fill out a separate time sheet for each project that they are appointed to. Commencing Summer Semester 2014, these timesheets will contain the following certification above the supervisor’s signature:
- “SUPERVISORS CERTIFICATION: I certify that services have been performed in a satisfactory manner and in accordance with University regulations during the period covered that this report is current in all details. If this Student Worker is grant funded, I further certify that all of the time reflected was spent on tasks in furtherance of the Grant Statement of work, BANNER ORG #__________________ and Grant Name___________________________________________.”
- The supervisor shall manually enter the Title and the BANNER Org. of the project on each timesheet to ensure that all work charged to the correct project. It is the supervisor’s responsibility to verify that all of the time noted on the timesheet was spent in furtherance of the statement of work of the Project title and BANNER Org. number noted on the time sheet. Timesheets for individual Student Workers will be provided each semester by Payroll.
- For Students compensated by Stipends, a Work Authorization Stipend Form shall be submitted prior to the start of work. The supervisor shall submit a Student Stipend Certification that notes the services performed by the student and certifies that services have been performed in a satisfactory manner and in accordance with the level of effort and tasks required by the grant statement of work. The Supervisor shall manually fill in the title and BANNER Org. # of the project to ensure that the activity is properly charged.
- For Graduate Assistants, a Graduate Assistant Work Authorization Form shall be submitted prior to the start of work each semester. The supervisor shall submit a Graduate Assistant Certification at the end of the semester that notes the services performed by the student and certifies that services have been performed in a satisfactory manner and in accordance with the level of effort and tasks required by the grant statement of work. The Supervisor shall manually fill in the title and BANNER Org. # of the project to ensure that the activity is properly charged.
5. Hiring and Paying Consultants: To hire an outside consultant on a grant, university policy requires a signed contract agreement between the university and the consultant. This policy can be found at: http://www.southernct.edu/offices/procurement-services/admin-support-services/psa.html.
The agreement should include the name, address, phone number, and Social Security number of the consultant, the Banner organization number, the duration of the agreement, the services to be provided under the contract, and the total compensation to be paid. A schedule of payment must be provided and the name of the university responsible monitor of this contract.
A W-9 form must be completed and submitted with the PSA. If the PSA is for a corporation, then a corporate resolution must be submitted showing that the person signing for the corporation was authorized by the board of directors to do so. The project director must prepare the PSA, forward the PSA to the contractor for signature, and forward the PSA to SPAR for approval. Then, SPAR will forward the PSA to Academic Affairs for the vice president's approval. The form will then be delivered to the Finance and Administration office for processing.
Payment requests for the consultant must be made by the project director on a voucher/disbursement request form, attaching the contractor's invoice, indicating the PSA number, in accordance with the payment schedule on the PSA. The voucher is then forwarded to SPAR for approval. SPAR, after approving the voucher will forward it to Accounts Payable.
6. Expenditure Approval: When it becomes necessary to make expenditures for carrying out the intent of the grant, existing university policy must be followed. The university policy for grant expenditures is explained in the "Finance and Administration Business Resources Manual." All grant expenditures, including purchase requisitions, voucher/disbursement request forms, personal service agreements, and honoraria, must be sent to SPAR for approval to ensure compliance with the budget as approved by the granting agency, as well as compliance with university policies and procedures. If SPAR finds an irregularity, the paperwork will be returned to the project director with an explanation of the problem. The project director is to correct the problem and return the document to SPAR. Detailed instructions for completing each of the expense forms are contained in the "Finance and Administration Business Resources Manual."
To assist the project director with grant spending, the following table will explain the forms used for grant expenditures. Detailed procedures regarding the preparation of these forms can be found on the Finance and Administration Policies and procedures page at:https://www.southernct.edu/offices/finance-administration/policiesprocedures/index.html
Purchase Requisitions Used for the purchase of materials and supplies. Documentation must be submitted before order is placed. See the Connecticut State University System Procurement Manual or Go to http://www.ct.edu/files/pdfs/policies-CSU%20Procurement%20Manual.pdf.
Honorarium (RFH) Used for the payment of guest speakers and lecturers. This form must be submitted 10 business days prior to engagement. See the Honoraria section of the Connecticut State University System Procurement Manual or the SCSU website at:http://www.southernct.edu/offices/procurement-services/admin-support-services/honoraria.html.
Personal Service Agreement (PSA) Used for contracting professional services. Under $3000, must be submitted to Finance & Administration department seven days in advance. Over $3000, including recurring PSAs which exceed $3000 cumulative over a 12-month period, must be submitted to Finance & Administration department 21 business days in advance AND requires approval of attorney general (This coordination is handled by Finance & Administration.). See the Connecticut State University System Procurement Manual or the SCSU website at:http://www.southernct.edu/offices/procurement-services/admin-support-services/psa.html.
Voucher/Disbursement Request Used for payment for an RFH or PSA, membership/ subscription renewal, stipends for non-employees participating in grant funded activities, etc.
Employee Voucher, CO-17XP Used for mileage reimbursement, employee out-of-pocket reimbursement ($100 maximum), and reimbursement for travel, etc. See Employee Reimbursement policy and remember! Sales tax is not a reimbursable expense.
Duplicating Services Request Form Used to charge a grant for University Duplicating services. Forms available in SPAR.
Mail Slips Used to charge a grant for postage and express mail services offered by the University Mail Room. Forms available in SPAR.
CSU Travel Authorization Used to authorize university-related travel. Must be completed and approved two weeks prior to travel. See Travel Policy at:http://www.ct.edu/files/pdfs/policies-TravelPolicyonlineversion2011.pdf.
Dual Employment Request Used when employee provides services for more than one state agency. See Personal Service Agreement section of F&A Business Resource Manual.
7. Financial Aid: When tuition payments need to be made from a grant, a justification in the form of an e-mail or memo with the student(s) name and student ID number(s) should be forwarded to SPAR for review. Please use the form for financial aid to include all of the information for the student(s) receiving financial aid via grant tuition payments.
SPAR will ensure that the charges are authorized by the grant and that the budget will support providing this aid to the students; then it will be forwarded to the Financial Aid office. The Financial Aid Office will insure that the tuition payment is deposited into the respective student's account.
8. Receipt of Grant Funds:
Grant funds from private organizations usually arrive in the form of a check made out to the university. In general, the check is delivered to the president or to SPAR. On rare occasions the check may be delivered to the project director. These checks may be for the entire granted amount or be in the form of installments. All checks must be brought to SPAR so they may be deposited within 24 hours of receipt into the Banner organization of the grant. If a Banner organization for the grant is not yet established, the funds will temporarily be deposited into a suspense account per regulations of the State Comptroller until the Banner organization is created. If SPAR is not available, and a deposit needs to be made, a deposit slip can be prepared for deposit into the "SUSPNS" (suspense account), in place of the F-O-A-P and brought to the Bursar's Office.
The pink copy will be given at the time the slip is received by the Bursar's Office. A yellow copy will be forwarded to the individual making the deposit.
Project directors who make a deposit must forward copies of the pink and yellow slips to SPAR so that the deposit may be recorded in the correct grant.
Grant funds that are improperly deposited into departmental Banner organizations will be lost at the end of the fiscal year. The project director will jeopardize the ability to access funds in the next fiscal year if this occurs.
Funding for most federal grants occurs on a reimbursement or "as needed" basis. University Accounting will track spending on federal grants and request reimbursements from the federal agencies (usually done quarterly).
Some agencies require an invoice in order to release funds for a grant. In this case, SPAR will prepare an invoice per the terms of the agreement with the agency. The projector director must work with SPAR by providing detailed information as to the completion of the applicable work, including the time period of the work and specifically what work was accomplished. This will ensure that the invoice is sent out according to the terms of the agreement.
9. Unallowable Costs on Grant Awards: Unallowable costs are those costs that cannot be charged to a sponsored project due to sponsor and/or SCSU policies, regulations and restrictions. Different sponsors have different policies, regulations and restrictions. The same sponsor could also have different restrictions for different awards, depending on the source of the funding, the type of award (e.g. grant, cooperative agreement or contract), or the purpose of the award (e.g. research, equipment, conference, training). Therefore, whether a cost is considered allowable or unallowable for a sponsored project can only be determined through a close review of the award documentation, sponsor regulations and guidelines, and SPAR policies and procedures. Check with SPAR before applying any of these expenses to a federal award, even if you feel you have an exception to the rule. Excellent documentation of unlike circumstances is crucial in an audit.
- Advertising and public relations costs (except in the case of recruitment for a position necessitated by the grant or public promotion of the grant activities)
- Alcoholic beverages
- Alumni/ae activities
- Bad debt
- Capital expenditures (>$5,000) not pre-approved by federal agency (may become allowable if approved by SPAR and the Funding agency)
- Commencement and convocation costs
- Computers and other technological devices, including cell phones, iPads, printers, etc. (unless demonstrably to be used for the purposes of a grant only and included in proposal budget submitted to federal agency)
- Contingency provisions
- Contributions or donations, including cash, property, or services
- Costs incurred in connection with any criminal, civil, or administrative proceedings
- Entertainment costs (even on business trips)
- Fines and penalties
- Food costs (except for study participants or meals while traveling that abide by normal university policies)
- Fund raising and investment costs
- Goods or services for personal use
- Housing and personal living expenses (except for study participants or meals/lodging while traveling that abide by normal university policies)
- Institutionally furnished automobiles or other vehicles
- Lobbying costs, at any level of government
- Losses on other sponsored agreements or contracts (it is not allowable to cover an over-expenditure on one grant by using funds from another)
- Memberships and subscriptions (except when necessitated by the grant)
- Office supplies (unless for a large printing project or mailing necessitated by the grant)
- Payroll for university employees not engaged in the grant’s activities
- Payroll in disproportionate amounts to the work performed on the grant (i.e. a research assistant working half her time on a research project may not receive more than 50% of her pay from that award)
- Postage (included in F&A, exception can be made if large mailing is necessitated by the grant)
- Professional service costs when work could be performed by qualified university personnel
- Proposal costs, including payroll for personnel working on the proposal
- Publication and printing costs (except when a research paper reports work sponsored by the federal government)
- Recruitment and relocation costs for employees not working on the grant (allowable for grant-funded employees; however, if employee resigns within 12 months of hire, recruitment and relocation charges related to that employee must be moved off the grant) ™
- Selling and marketing costs
- Student activity costs (unless specifically provided for in the grant award)
- Telephone--local charges (included in F&A, long distance charges for specific purposes of the grant are allowable)
- Tuition & fees (except for training grants or tuition remission as, or in lieu of, pay for graduate students working on that particular grant)
10: Indirect Costs: The federal government recognizes that in addition to the direct costs that can be specifically identified with a particular grant, there are other costs incurred which are common to two or more of an institution's projects or operations. These costs are called indirect costs, and the government has issued a set of federal cost principles to determine what portion of these common costs can be allocated to grants sponsored programs.
Generally, indirect costs include the cost of the operation and maintenance of the physical plant (such as security, utilities, and depreciation), general administrative costs of the university, fringe benefit costs, and library costs.
In general, the federal guidelines prohibit the inclusion of athletic expenses, student activity expenses, development expenses, rare book expenses, and all expenses related to auxiliary services in the computation of indirect costs.
Indirect costs are charged to the grant whenever allowed by the granting agency. The U.S. Department of Health and Human Services calculates the indirect cost rate for SCSU. The current indirect cost rate is 65% of salaries exclusive of fringe in the grant. This rate is in effect until June 30, 2016.
The Accounting Office prepares an indirect cost proposal using the prescribed federal guidelines and submits the proposal to the Department of Health and Human Services (HHS). Unallowable indirect costs are eliminated from the indirect cost rate calculation by pulling annual expense summaries by account codes that correspond to all un-allowed costs per A-21, and eliminating these amounts from the facilities & administrative cost pools that are part of the rate calculation. In addition, on an ongoing basis expenses are reviewed throughout each fiscal year to ensure the account code classification is correct, and detailed reports are re-reviewed for the rate calculation to ensure elimination of un-allowed costs.
HHS negotiates with SCSU on behalf of all the federal granting agencies to arrive at an acceptable indirect cost rate. Once an agreement has been reached between HHS and the university, the new rate becomes our indirect cost rate for a set period of time. This rate is usually stated as a percentage of direct salaries and wages in a proposed grant budget.
Recovered Indirect funds shall be allocated internally as follows:
- 20% to account for use of the Dean of the P.I.’s School to encourage Grant activity in the School.
- 20% to account for use of the P.I. This account may not be used to pay the P.I. but may be used to purchase, student labor, Graduate Assistants, equipment or supplies for use in the P.I.’s research, teaching or department.
- 10% to account for use by SPAR to be used in support of Grant activity including events, travel and training.
- 40% Finance and Administration
- 10% Provost
The University Accountant is responsible for the above indirect draw downs and distributions
11. Reports: Based on the requirements of the grant, the University Accounting Office will prepare and submit all required financial reports after reviewing them with SPAR and the P.I. to ensure accuracy.
It is the responsibility of the project director to file required progress and final project reports with the granting agency, as well as ensure that the financial reports are submitted in a timely manner. Continued funding depends on the caliber of these reports; they are as important as the proposal and can set the stage for future awards. Report copies must be given to SPAR. Failure to file these reports in a timely manner reflects poorly on the university and may delay the flow of funds from federal agencies, not only for your project but also for all federally supported grant projects.
12. Payments to Foreign Nationals: Policy Regarding Payments to and for Foreign Nationals on Grants.
The following are the procedures set forth by Southern Connecticut State University with regard to payments on grants and contracts to foreign nationals. It is the responsibility of the principal investigator (PI) of the grant to properly present voucher/disbursements, personal service agreements, honoraria, and purchase requisitions to the SPAR Office on a timely basis in order to properly process these payments. Voucher/disbursements, personal service agreements, honoraria, and purchase requisitions received by Finance and Administration without approval from SPAR will be returned to SPAR, delaying processing of the expenditure. Under no circumstances will faculty or staff be reimbursed for any cash payments made to foreign nationals.
A. Travel Expenses to Foreign Nationals:
When foreign nationals travel to and from Southern Connecticut State University for purposes of grant activity, travel expenses shall (whenever possible) be prepaid by purchase order to include hotels, airfares, and other transportation. The purchase requisition which initiates the purchase order shall reflect the organizational number of the grant activity, and shall be submitted no less than four weeks in advance of the intended travel. Purchase requisitions shall include a complete justification for the travel being requested and shall be authorized by SPAR before being presented to the Purchasing Department. Advances for meals shall be made by calculating the per diem (See Note below) for the city intended times the number of days the foreign national is in residence and shall be processed on a voucher/disbursement. The voucher/disbursement must be accompanied by copies of supporting documentation and must list the associated organizational number.
Note: To calculate the per diem, please refer to the following Web site: https://secureapp2.hqda.pentagon.mil/perdiem/pdrates.html
If airfare is involved, the SPAR Office will assist you in making arrangements in accordance with the Travel. Copies of arrangements made must accompany the purchase requisition, and the description area of the purchase requisition must indicate "pre-payment order” or may be paid with a P-Card.
When time or extenuating circumstances will not allow prepayment of travel expenses through the purchase order process, reimbursement shall be made to foreign nationals through the use of a voucher/disbursement on an actual basis, but not to exceed the budgeted amounts. Original receipts shall be presented, translated into English and United States currency rates, along with a voucher/disbursement as proof of the expense. A complete justification must accompany the voucher/disbursement detailing the nature of the expense, and the reason why prepayment could not be made.
Whether travel for foreign nationals is paid by purchase order or by voucher/disbursement, all requests must be accompanied by a copy of the grant budget showing the necessity and authorization for the travel by the grantor and the SPAR Office.
B. Payment of Stipends to Foreign Nationals:
Payments of stipends to foreign nationals shall be processed on a voucher/disbursement
with an attached justification explaining the source and purpose of the expenditure.
As in travel payments, the voucher/disbursement must be accompanied by a copy of the
budget of the grant, showing stipend payments as an approved and necessary expenditure.
SPAR approval must be evident before stipend voucher/disbursements will be processed.
PLEASE NOTE: The payment of stipends to foreign nationals does not preclude the personal service agreement process. Stipends are provided only if a service has not been provided to the university. If a service is to be provided to Southern Connecticut State University, such request for service must adhere to the policies and procedures related to bidding practices and signature requirements related to the processing of a personal service agreement. Please refer to the section related to personal service agreements contained within the Finance & Administration Business Services Resource manual regarding personal service agreement procedures for more information.
C. Payment of Salary to Foreign Nationals:
Foreign nationals hired as employees of Southern Connecticut State University must be hired under the same human resource processes as all other hires. Be advised that these employees may be subject to a higher withholding rate than other employees by United States Department treaties. These withholding rates are not discretionary and must be followed in order for the university to comply with Internal Revenue Service regulations. Many foreign nationals require permission to work from the person responsible for issuing their travel documents. It is the PI's responsibility to consult with Southern's Office of Human Resources and the SPAR Office to determine the correct United States visa class for a visitor who intends to work at Southern. PI's are also advised that entrance to the United States under certain visa classes may preclude foreign nationals from returning under a different visa class for up to two years. The visitor is responsible for inquiring as to the impact of their chosen visa status with the U.S. Embassy.
For direction on the procedures for hiring human resources, including forms and instructions,
please see the Human Resources Website, located by clicking the "Faculty & Staff"
button on the Southern Connecticut State University home page (www.southernct.edu). Under no circumstances may a foreign national begin work as an employee at Southern
Connecticut State University without written approval from the Office of Human Resources.
D. Acquisition of Goods/Commodities for Foreign Nationals:
For those grants that require the purchase of equipment or other commodities, the policy and procedures regarding bid and acquisition practices for Southern Connecticut State University must be adhered to. Reimbursement may be provided, with proper receipts translated into English, for the purchase of commodities or services which do not exceed a total of $100, as is in accordance with the university's reimbursement policies.
13. Close-Out: When a grant closes, there are several steps to follow to ensure that the grant is closed properly and in a timely manner. It is essential that the project director meet with SPAR at least 30 days prior to the end of the grant to ensure a smooth closeout. At this time, current grant charges will be reviewed, all required reports and due dates will be determined, and the submission of final grant expenditures will be discussed.
Once all grant expenses have been paid, remaining revenue in cost reimbursement grants will be returned to the agency, and remaining revenue in Fixed-price grants will become the property of the university (see section on Fixed-Price Contracts vs. Cost Reimbursement Contracts.) When the Banner organization has a zero balance, the University Accountant will close out the Banner organization account.
14. Records retention: SPAR shall retain administrative and financial records on grants in accordance with the State records retention schedule. To ensure that the records of Federal Grants (which may have a differing retention requirement) are properly retained, SPAR will indicate on the initial and any subsequent revised GADS the specific number of years that financial and administrative records are to be retained.
- For the National Science Foundation, Financial records, supporting documents, statistical records and other records pertinent to a grant will be retained by the grantee for a period of three years from submission of the Final Project Report described in GPM 342, "Final Project Report," except that:
- records related to audits, appeals, litigation or the settlement of claims arising out of the performance of the project will be retained until such audits, appeals, litigation or claims have been disposed of; and
- records related to projects subject to special program income provisions (GPM 753, "NSF Policy") will be retained for three years beyond the end of the award period.
- For the National Institutes of Health, Grantees generally must retain financial and programmatic records, supporting documents, statistical records, and all other records that are required by the terms of a grant, or may reasonably be considered pertinent to a grant, for a period of 3 years from the date the annual FFR is submitted. For awards issued under the SNAP authorities, the three-year retention period is calculated from the date the FFR is submitted for the entire competitive segment.
- For all other Agencies, SPAR shall note on the GADS both the period of retention and the date from which that period is counted.
15. SCSU Journal Entry Procedures: Occasionally, charges may need to be transferred between ORG#s. Transfers can happen in two ways:
- It may happen that an unallowable cost or a cost item that belongs in a different ORG# will be discovered in a Grant ORG when SPAR reconciles accounts each month. When unallowable or erroneous entries are discovered, SPAR will contact the PI to determine which ORG# to transfer the charge. These are Manual Banner Entries: They begin by having the PI fill out the standard journal entry form or expense transfer request form for grants for entry into Banner. All information, including the justification must be filled in before the form is reviewed and checked by the SPAR office to ensure that charges belong in the ORG# they are directed to. If the expense transfer request involves payroll expenses, a Time & Effort Report must be filled out and provided to SPAR. Upon approval by SPAR for processing, SPAR will keep a copy in the file for documentation and will forward the form to University Accounting to process the expense transfer. The form is checked in accounting and the journal entry is posted by the grant accountant. Two signatures are required for all journal entries — one by the originator (the person actually posting the journal) and one by the reviewer/approver. Copies of the Expense Transfer Request Form will be returned to SPAR by University Accounting once posting is complete. This also pertains to reversing an incorrect journal posting in Banner. In this case a correcting journal entry is prepared to reverse the original journal entry, and two signatures (one by the originator and one by the reviewer) are required on the reversing journal entry. A similar standard form and procedure is used for Core journal entries.
- Recurring transactions, such as the automated postings for expense allocations of the following: postage, duplicating, Staples office supplies, the Facilities / Auxiliary charge-back transactions, P-card transactions and others use Automated Banner Journal Entries which utilize an automated data entry form that has been setup for these large routine transactions. The allocation data for these transactions are compiled and checked by the source administrative departments and rechecked in Finance before and after being posted through an automated process. They are checked again in SPOAR’s monthly reconciliation of SPAR records and BANNER postings of approved transactions. These journal entries are not posted manually, but an automated process set up by the IT department posts the transactions, with reviews taking place at both the administrative and finance department levels. If an automated journal entry has to be reversed, a manual journal entry form covering the reversal is prepared by referring to the original detailed journal entry, and it is reviewed and signed by both the originator and the reviewer before entering the reversal through the automated journal posting process in Banner
17. SCSU Grants Accounting Procedures
Creating a New Grant in Banner - SPAR will send the Banner Organization Create Request form to University Accounting, along with supporting documentation (including the grant agreement) for the grant period, the grant amount, and any reporting and invoicing requirements. The original GADS is also included, so that the budget can be posted in Banner once the org is created. The Grants Accountant reviews the org create request and the GADS, agreeing the information to the grant agreement and checking the mathematical calculations. Once any questions are answered, the Grants Accountant forwards the request to the Controller, who creates a new org number in Banner and returns the processed request to the Grants Accountant. The Grants Accountant then prepares the budgeting entry on an Excel template provided by Budgeting and delivers the GADS and the prepared entry to Budgeting. Budgeting posts the new grant budget in Banner. The Grants Accountant notifies SPAR of the new Banner org number.
Grant Budget Revisions - When a revision to a grant budget is needed, SPAR sends the revision request on a new GADS to the Grants Accountant. This GADS has three columns: the Previous Budget, the Revised Budget, and the Change column. The Grants Accountant agrees the Previous Budget column to what has already been posted to Banner and reviews the calculations. Once any questions have been answered, the Grants Accountant prepares the necessary budget entry and brings the prepared entry and the GADS to Budgeting. Budgeting posts the revision to Banner, and the Grants Accountant notifies SPAR when the revision has been posted.
Drawdowns and Reporting- University Accounting does all invoicing and drawdowns for grants. The NSF grants require an account to be set up on the Research.gov website for reports and drawdowns. The financial reports and drawdowns are done on the ACM$ system, which is accessible through Research.gov. The Grants Accountant prepares a report/drawdown quarterly if there are applicable expenses, based on actual expenses posted to the grant in the Banner system. After the Grants Accountant prepares the report/drawdown in ACM$, documentation for the transaction is provided to the Director of Accounting Services, who reviews, certifies and submits the ACM$ transaction. The grant funds are sent to the Office of the State Comptroller, where the funds are deposited in the University’s Fleet account and transferred in the CoreCT system to the University. The Grants Accountant monitors CoreCT and posts the deposit in the CoreCT system. Once the CoreCT transaction is complete, the Grants Accountant prepares the revenue posting entry for Banner. The Director of Accounting Services reviews and approves the entry, and the Grants Accountant posts the entry in Banner.
Unallowable Costs- Before a final report is completed; the Grants Accountant will provide a summary of all expenses under the grant to the PI and SPAR for review. Similar reports are also provided throughout the grant as requested. When costs posted to the grant are identified as unallowable, the Grants Accountant works with SPAR to determine which Banner org (cost center) the expense should be transferred to. This ensures that only actual grant expenses are posted to the grant’s Banner org.
Record Retention- The Grants Accountant follows the State’s record retention policy requiring documentation to be maintained for three to five years (depending on the type of document). In most cases, the documentation provided to the Grants Accountant are copies, not originals. These can be destroyed when they are no longer needed, though the Grants Accountant maintains these records for five years in case of any follow-up questions after the grant is closed. SPAR includes a notation on the GADS indicating that retention on the grant documents is required for three years.
Page revised December 27, 2014