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Financial Compliance with Extramural Funds

The Principal Investigator (PI) is the individual with primary responsibility for:

• The scientific integrity and management of the sponsored project
• Financial management of project funds
• Adherence to all internal University policies
• Adherence to externally imposed sponsor terms and conditions including reporting and record keeping requirements contained in the award document.

• Ensuring the allowability, allocability and reasonableness of all expenditures; only costs which benefit the project may be charged to the project
• Ensuring that expenditures direct charged to sponsored project are consistent with the approved budget and not duplicated in the Facilities and Administrative (F&A) Cost Rate such as administrative and clerical salaries (unless the cost is associated with a major project as defined in A-21 Exhibit C)
• Requesting the establishment of an advance account if a delay in receiving an award is expected and project work must begin before the award is executed. Use the request to expend in advance of receipt of award mechanism. Reference: UC Davis Policy and Procedure Manual Section 230-06, Advance Account Request.
  • Process eliminates necessity of cost transfers
  • Provides for expedited reimbursement of expenses incurred once the award is received (no delays due to cost transfers)
  • Must guarantee funding for expenditures incurred if the award is not executed
  • If funding period differs from what was expected, pre-award costs may not be allowed
• Reviewing monthly and/or daily reports and identifying and resolving errors on the account in a timely manner
• Monitoring financial status of project…are expenditures aligned with project period and progress?
• Reviewing effort reports and certifying effort in a timely manner
• Submitting all required reports on a timely basis (progress reports/technical reports)
• Ensuring that cost transfers are minimized and when necessary are initiated within 120 days of the original recording of the expense
• Requesting no-cost extensions in accordance within timeframe specified by agency if more time is needed to complete project
• If appropriate at budget period end, requesting remaining balances be carried forward
• Ensuring overdrafts on one sponsored project are not transferred to another sponsored project because of funding availability. Direct costs charged to project must always benefit/support the project charged
• Preparing for timely financial closeouts…process begins at the beginning of the award by managing project funds on a continuing basis
• 90 days before award end date prepare for final report submissions. Most awards require that a financial report be filed 90 days after award end date
• Ensuring that equipment reporting requirements are fulfilled…..know the terms and conditions of the award
• Ensuring cost sharing commitments are met
• Monitoring subcontracts issued under prime agreement
• Ensuring the appropriateness and accuracy of all effort expended on the sponsored project by certifying direct-charged and committed cost-shared effort. Effort certified on sponsored projects must be reasonable and reflect actual effort in relation to all other university activities that you are engaged in

• Office of Management and Budget Circulars
  • A-21 Costing Principles for Educational Institutions
  • A-110 Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations
  • A-133 Audits of State, Local Governments, and Non-Profit Organizations
• Agency Guidelines and Policies (see individual agency websites)
• Award terms and conditions contained in the award documents

• UC Davis Administrative Policy and Procedure Manuals
• Charging Practices for Federally Funded Grants & Contracts (rev. 2009)
• Contract and Grant Manual
• Administrative Responsibilities Handbook
• UCD Extramural Funds Accounting
• UC Davis Office of Research
• UCOP Research Administration Office
• UC Davis Academic Personnel Manual