Financial Management Processes
Financial Management Processes
Research Accounting provides daily institutional oversight of grant and contract expenditures to ensure compliance with OMB circulars, FARS and other federal and state laws, regulations and policies that govern the expenditure of sponsored funds.
To ensure that sponsored project expenditures, revisions, Payroll and other devices that have a financial impact on sponsored projects are being documented and charged as to satisfy the terms and conditions of each award. In addition, Research Accounting has an obligation to the University to ensure that reimbursement from sponsors are received in a timely manner and to ensure that sponsored project ledgers are being kept in accordance with Generally Accepted Accounting Principles.
Financial Management Responsibilities
Research Accounting (RA) is responsible for assisting the Principal Investigators in the day to day financial monitoring, review, and expenditure approvals for all sponsored projects.
Monthly Process Responsibilities
Research Accounting (RA) is responsible for the indirect allocation and direct allocation processes in Business & Finance in order to for the university to close the financial period each month. After the final closing, Research Accounting must prepare and submit reconciliations of all Fund 20000 and Fund 15000 accounts to the Division of Business & Finance. In addition, the department prepares and submits monthly invoices and documentation to the respective sponsors. Monthly financial reports are prepared and emailed to each Principal Investigator. Certification of effort for key personnel on federally sponsored awards is managed by the department of Research Accounting each semester and kept on file for audit purposes.
Daily Grant Management Procedures
|Educating PIs and Department Administrative Staff||Research Accounting personnel spend a great deal of time educating PIs and administrative personnel who assist the PIs on items such as: processing travel expenses, purchasing items in the Marketplace, purchasing of items from vendors outside of the Marketplace and getting the vendors set up in the vendor database, submitting POs, payment requests, hiring processes for different types of employees, etc.)|
|Requesting and/or Approving Grant Access to various university systems||Any access to sponsored project funds or sponsored project financial reports must be approved by the PI and Research Accounting|
|Review and Approval of Expenditures||Research Accounting must review and approval (or deny) all of the following with regards to expenses on sponsored projects, including (but not limited to):|
-Georgia First Marketplace orders
-Special Requisitions in ePro
-Travel Expense Reimbursement Requests
-Per Diem & Fee Requests
-University Store / Tech Store charges
-Printing and Postal charges
|Hiring personnel on sponsored projects||Research Accounting requests any student assistant position, GAs, and part-time employee position number establishment in coordination with the Budget Office. Once a position number is established and updated in the HR system, the department submits a position hiring request (for student assistants and part-time employees) in which RA reviews/approves. |
Once the PI is ready to hire, the department submits a hiring proposal (student assistants and part-time employees) or electronic PAF (for GAs) in which RA reviews/approves. An Invalid Funding Report must be run weekly to ensure that funding is available on the lines in which individuals are hired. If a grant position shows up on the report, the RA researches the cause and works with the department to determine if they need to add funding to the line, change the employee to another position, or submit a termination PAF.
Research Accounting works with PIs and department administrative personnel to determine the amount of summer salary each individual on a grant may receive. This amount is not always determined by the amount listed on the fact sheet. The approved salary budget is an estimate based on projected salaries at the time of the proposal. Therefore, if the award indicates a percentage, calculations must be done to determine the correct, allowable amount to be charged. RA must approve all termination or hiring PAFs that involve sponsored project accounts.
|Budget Transfers||Transfer of funds between project budget categories is done according to the sponsor guidelines and OMB cost principles. If prior approval is required, the grant coordinator will contact the sponsor for approval. Sponsor approval is then forwarded to research accounting. In coordination with the PI, a sponsored budget transfer request form is completed, and approved by the PI, department chair/dean, and research accounting. The budget is then adjusted accordingly in Peoplesoft and an updated Fact Sheet showing the changes is sent to the PI and appropriate administrative personnel.|
|GA Tuition Payment Process||For grants that include tuition costs for a GA, Research Accounting requests the GA Tuition Payment form from the PI/department. After verifying the number of credit hours for which the student is registered, Research Accounting enters the amount of tuition that is allowed to be charged to the grant and forwards the form to the Bursar’s office for their input as to the manual waiver amount. The form is then returned to Research Accounting, who creates and processes the journal to charge the tuition to the grant.|
|Payroll Reallocations||If payroll is charged in error to a project, or if payroll should have been charged and was not, Research Accounting with work with the PI and department administrative personnel in order to have the error corrected on a Payroll Reallocation form. Research Accounting monitors subsequent payroll reports to ensure that the reallocation is properly charged and documented.|
|Deposits||Research Accounting prepares and processes deposit transmittals for Sponsored Project Grant payments from RSF and other sponsors. After the Cashier’s office has signed in acknowledgment of check receipt, Research Accounts journals the deposit. The Accounts Receivable spreadsheet is updated to include the receipt of funds for each specific invoice that corresponds with the deposit.|
|Grant Revisions||Research Accounting updates sponsored project grants in Peoplesoft and when notification and CX award documentation is provided by Research Services staff. This includes no-cost extensions, PI changes, budget revisions, and additional funding. An updated fact sheet is then emailed to the PI with the appropriate backup documents.|
Research Accounting Monthly Process Procedures
|Indirect Allocation Process||In the F&A database, move previous period data to current period data;|
Run F&A Cost Distribution by Grant and make sure to correct any speed chart errors;
Print and Open the F&A Cost Recovery table and be sure that any F&A adjustments for the period are recorded; Run Process for F&A GL Journal and make sure that debits and credits correspond. Import Journal file;
Run F&A Budget Distribution process and verify the total allocated less Foundation equals the total from F&A GL Journal;
Run Fund 15000 Budget Distribution Journal Report and verify there are no zero dollar amount lines – if there are, delete these before saving as text file;
Run F&A Cost Distribution by Grant process;
Upload the indirect journal in PeopleSoft. If an error exists when uploading, Research Accounting must research the line(s) causing the error(s), then re-run the process to upload;
After the journal has been successfully uploaded, Research Accounting runs the process to print the F&A Cost Distribution letters and distributes them to the appropriate personnel;
The Fund 15000 Budget Journal Report and text file is emailed to the Budget office and the Direct Allocation process can begin.
|Direct Allocation Process||Research Accounting runs the Grant Revenue process in PeopleSoft; |
Looks up the Direct Journals and runs the edit and budget check processes;
Any errors are reviewed and corrected errors until no errors are received;
After the Grant Revenue process is complete and posted, a BOR Audit Trial Balance query is run as a control check point;
A pivot of the query is created and filtered to remove zero balances, then compared to the Balance Sheet by Fund Query;
The Associate VP for Business & Finance and other financial accounting personnel are notified that the grant allocations are complete and they can proceed with month end closing.
|Invoicing RSF and other Sponsors||RSF Invoicing: The Grant Bill process is run in PeopleSoft and invoices are printed on pre-numbered invoice letterhead. Research Accounting provides backup documentation to each invoice and checks the accuracy of all charges before providing a scanned copy and a hard copy of the signed invoices and backup documentation to the Research Services Foundation. Several Peoplesoft queries are extracted, merged, and formatted with expense/invoice information pertaining to RSF projects. This spreadsheet is then provided to RSF as well. |
Other Sponsor Invoicing: Manual invoices are created for sponsors other than RSF. These are created on pre-numbered department letterhead as well. Backup documentation to support the invoice is printed and the invoice is signed by the accountant and Business Manager, then mailed/emailed to the sponsor.
|-Fund 20000 Reconciliation|
-Fund 15000 Reconciliation
-BOR Aging Report
-RSF Accounts Receivable Aging Report
|Each of these reconciliations and reports involve running multiple Peoplesoft queries, pivoting data, formatting, filtering, running check point processes, and comparing against the corresponding account numbers in the University’s monthly trial balance. |
Any checkpoint differences must be analyzed, corrections made and documented before being finalized.
The final reconciliations must be approved by RA and B&F, then scanned into the Financial Accounting folder on the drive.
|Cost Share Updates||Research Accounting monitors cost matching account expenditures and runs monthly reports for all projects that have cost match. The respective cost share tracking spreadsheet on the drive is then updated. Research Services Foundation has access to the files and will notify Research Accounting if there are questions or if additional documentation as needed.|
|PI Monthly Emails||Research Accounting runs Business Objects Reports for the PIs each month (after the month-end close process is complete). An email is sent to the PIs with the reports attached. PIs then contact RA with questions or to address any specific items of concern.|
|Royalty Accounts||Research Accounting runs expense queries each month on all royalty accounts. Manual invoices are created, expense documentation is gathered, and then sent to RSF for payment.|
|Effort Certification (once a semester)||Effort on all federal grants must be certified by the PI each semester. Research Accounting prepares the Effort Certification reports based on payroll reports on each faculty member paid from the project. The reports are then sent to the PIs and they must review, sign, and return them to Research Accounting.|
Grant Management Resources
Grant Management Related Policies and Procedures
|Federally Sponsored Effort Documentation Policy – FS-RA-2103-01||The purpose of this policy is to establish guidelines and procedures for documenting personnel (faculty, staff, and students) charged to federally sponsored grants and contracts.|
The OMB Uniform Guidance, 2 C.F.R. Part 200.430, paragraph (i) states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. This code sets forth standards for documentation of personnel expenses charged to Federal awards. Research Accounting prepares and distributes effort certification reports via email to the PI for salaries and wages charged to federally sponsored grants and contracts either as a direct charge or as a cost shared commitment. These reports are based on payroll records and are distributed within forty-five (45) days following the end of the Spring and Fall semesters and within sixty (60) days following the end of the Summer semester.
The reporting periods are as follows:
● Fall Semester – August 1 through December 31
● Spring Semester – January 1 through May 31
● Summer Semester – June 1 through August 31
Other reporting time frames will be taken into account if required by sponsoring agencies.
Included in this process are salaries paid to faculty, administrative professionals, bi-weekly paid staff, graduate assistants (GAs, RAs, TAs), and bi-weekly or monthly-paid temporary staff. Also included in this process is any overload salary paid or extra compensation paid for University commitments.
Extra compensation paid for incidental work that is in excess of base salary is included in the effort calculation to ensure consistency in reporting.
Effort reports reasonably reflect the percent distribution of efforts expended by these groups on federally funded grants, contracts, and cooperative agreements and account for 100% of an employee’s actual effort for the given time period. Any deviation in reported effort of greater/less than 5% should be reported to the Office of Research Accounting for review and correction.
The recipient of an effort report should certify his/her own effort report unless the employee is no longer available to certify. In this event, the Principal Investigator, or a person with direct knowledge of the employee’s workload, must certify the report. Effort reports should be returned to Research Accounting within thirty (30) days of receipt. Research Accounting accepts original signatures returned via campus mail, approved and scanned reports via email, or in the instance that the faculty and staff are away from campus, an emailed approval from the faculty or staff will be accepted and attached to the effort report.
Reminder emails are sent to the PI by Research Accounting staff when reports are not received within thirty (30) days. If effort reports are not received within forty-five (45) days, the delinquent reports are referred to the Department Chair and College Dean of the respective employee’s department.
Any effort reports that remain uncertified upon distribution of reports for the next reporting period are subject to additional scrutiny, and the salary portion that was charged to any federal source will be reallocated to alternate funding. The alternate funding will be applied in the following order of availability:
(1) Principal Investigator F&A account
(2) Departmental F&A Account
(3) College’s F&A Account
(4) Other Departmental Budgets
|Principal Investigator Responsibilities – RSSP 103||This document stipulates the responsibilities of principal investigators in managing their sponsored projects.|
Authorization of Direct Charges
To authorize expenditure of funds charged directly to sponsored projects, the PI and the department must assure:
the estimated charge is reasonable and necessary;
the expenditure is allowable per the funding source and, if federally funded, per OMB Circular
the expenditure is allocable to the project; that is, it benefits the project;
the funds are available within the authorized award amount and limits;
the justification for the expenditure is documented;
allocation of costs is appropriate and documented; and
the charge has been processed through the appropriate university system.
Review of Project Expenditures
Business Objects reports are a valuable tool for project oversight. They should be reviewed each month by a knowledgeable individual—the PI or designee—so adjustments are timely, and expenditure rates can be monitored to assure availability of funds. Any questionable charges must be brought to the Research Accountant’s attention promptly and corrected by an appropriate reallocation (transfer), if necessary. Reallocations should be initiated as soon as possible after a need is identified. Whenever expenses are moved to or between sponsored accounts, the PI must assure that the project that pays is the project that benefited, supported by documentation.
Charging Salaries to Projects
Salary charged to sponsored projects must be supported by documentation of appropriate level of effort. The PI is responsible for ensuring that effort reports for the project are submitted in a timely fashion.
Monitoring Funds within Sponsor Funding Limits
PIs are responsible for ongoing fiscal management of their awarded projects, including regular monitoring against project period budgets. Federal grants policy Uniform Guidance, 2 CFR 200, establishes the approved project budget as the financial expression of the project, and sponsors may evaluate the project against the budget at any time. Although sponsors allow certain flexibilities in re- budgeting, unobligated balances, and pre-award costs, both they and Georgia Southern expect expenditures to be reasonably consistent with the approved project and budget. Sponsors may question or restrict expenditures that appear inconsistent with the project plan and budget.
The PI is responsible for requesting prior approval when revisions to the project plan or budget indicate a significant change in scope. Indicators include significant expenditures beyond the amount authorized in the award or requests for additional funding.
Georgia Southern policy holds that a sponsored project will be managed within the established budget. If, as a result of unusual circumstances or unanticipated project expenses, an account is in overdraft at the end of the period of performance, and additional funds have not been received from the sponsor, the PI, with the department chair and/or college dean, must identify an appropriate source of funds (e.g., gift, endowment or departmental funds) to cover the expense. The overdraft must be transferred in time for the university to comply with the original award’s financial reporting requirements.
The PI is responsible for monitoring the work effort of subrecipients and consultants. PIs should carefully review invoices submitted by subrecipients to verify that the level of effort and items expensed against the project are appropriate to the quality and quantity of work provided. By approving an invoice, PIs indicate that the charges appear appropriate, and work is progressing as planned. Inappropriate expenses and/or problems with performance should be reported immediately to Research Services.
No-Cost Time Extensions and Other Administrative Actions
If additional time is needed to complete a project, the PI may request that the period of performance be extended. In some cases, Research Services is authorized to approve no-cost time extensions; in other cases, prior approval from the sponsor is required. The PI should initiate extension requests before ninety (90) days prior to the end date in accordance with the terms of the sponsored award; in most cases, the countersignature of an authorized institutional office is required. To ensure compliance with the award’s reporting requirements, PIs are urged to submit no-cost time extension requests as soon as the need becomes apparent. If final technical reports must be completed after the project end date, the PI should obtain a no-cost extension from the sponsor to produce and distribute the reports. If project funds are not available, the PI, department and/or college must identify unrestricted funds to pay final report costs.
The PI is also responsible for identifying and requesting (through Research Accounting and/or Research Services) other administrative actions, such as re-budgeting, changing project personnel, reducing PI effort, and similar actions.
The PI must ensure that all deliverables, including reports, are completed as outlined in the award and submitted as scheduled. If a deliverable or report is not submitted through the sponsor’s electronic portal, the PI should provide a copy of the report or the transmittal letter (or email) to the grant coordinator, so the university has a record of submission.
The PI is responsible for overseeing proper closeout of sponsored projects, including timely submission of all required reports (including final technical reports). While central offices prepare and submit final administrative reports, including financial and property reports, they rely on documentation created in the department or by the PI. PIs must assure that this documentation is adequate and readily available. In addition, PIs are responsible for ensuring that any necessary final financial adjustments and documentation (e.g., final invoices from vendors or subrecipients) are received promptly after the award ends. If invoices or expenses are received after submission of the final financial report, submitting a corrected invoice may not be possible.
|Sponsored Expense/Cost Transfers Policy – FS-RA-2101-01||To define expense/cost transfer policy for federal grants and contracts to assure compliance with all applicable federal and state laws.|
Expense transfers must be timely, conform to university and sponsor guidelines and have appropriate documentation to be considered allowable. Frequent, late, or inadequately documented transfers raise questions about the propriety of the transfers and may result in expenditure disallowances and/or subsequent reduction in funding.
Sponsored project funds should be reviewed by the Principle Investigator (PI) on a monthly basis to ensure that all expenditures charged are correct and appropriate. It is the responsibility of the principal investigator to authorize transactions and review the expenditures for accuracy. If an error is discovered, an expense transfer should be made no later than 60 days after the original transaction or 30 days after the end of a project, whichever comes first. To request an expense transfer, the PI or department should complete the Expenditure Transfer Form. Acceptable documentation of the expense transfer include, at a minimum:
1) The completed expense transfer form. The form must include an explanation to fully document how the error occurred and a certification of the correctness of the new charge by the PI or responsible party if PI is absent. An explanation merely stating that the transfer was made “to correct error” or “to transfer to correct project” is not sufficient.
2) Business Objects Financial History report showing the original charge
3) Approval by PI and Budget Manager of the budget of the original charge.
The completed form should be sent to Research Accounting for review and posting.
Under no circumstances is it appropriate to initiate an expense transfer for the sole purpose of utilizing unexpended funds or to cover losses or overages from other projects. Federal regulations specifically prohibit transfers of this nature.
Federal regulations governing expense transfers:
2CFR220.C.4.b (OMB Circular A-21 C.4.Allocable Costs) – “Any costs allocable to a particular sponsored agreement under the standards provided in this Appendix may not be shifted to other sponsored agreements in order to meet deficiencies caused by overruns or other fund considerations, to avoid restrictions imposed by law or by terms of the sponsored agreement, or for other reasons of convenience.”
NIH Grants Policy Statement, Part II: Terms and Conditions of NIH Grant Awards, Section 7.5 Cost Transfers, Overruns and Accelerated and Delayed Expenditures
“Cost transfers to NIH grants by grantees, consortium participants, or contractors under grants that represent corrections of clerical or bookkeeping errors should be accomplished within 90 days of when the error was discovered. The transfers must be supported by documentation that fully explains how the error occurred and a certification of the correctness of the new charge by a responsible organizational official of the grantee, consortium participant, or contractor. An explanation merely stating that the transfer was made “to correct error” or “to transfer to correct project” is not sufficient. Transfers of costs from one project to another or from one competitive segment to the next solely to cover cost overruns are not allowable.
Grantees must maintain documentation of cost transfers, pursuant to 45 CFR part 74.53 or 92.42, and must make it available for audit or other review (see Administrative Requirements— Monitoring—Record Retention and Access). The grantee should have systems in place to detect such errors within a reasonable time frame; untimely discovery of errors could be an indication of poor internal controls. Frequent errors in recording costs may indicate the need for accounting system improvements, enhanced internal controls, or both. If such errors occur, grantees are encouraged to evaluate the need for improvements and to make whatever improvements are deemed necessary to prevent reoccurrence. NIH also may require a grantee to take corrective action by imposing additional terms and conditions on an award(s).
The GMO monitors grantee expenditure rates under individual grants within each budget period and within the overall project period. The funding that NIH provides for each budget period is based on an assessment of the effort to be performed during that period and the grantee’s associated budget, including the availability of unobligated balances. Although NIH allows grantees certain flexibilities with respect to rebudgeting (see Administrative Requirements— Changes in Project and Budget), NIH expects the rate and types of expenditures to be consistent with the approved project and budget and may question or restrict expenditures that appear inconsistent with these expectations.
The GMO may review grantee cash drawdowns to determine whether they indicate any pattern of accelerated or delayed expenditures. Expenditure patterns are of particular concern because they may indicate a deficiency in the grantee’ s financial management system or internal controls. Accelerated or delayed expenditures may result in a grantee’s inability to complete the approved project within the approved budget and period of performance. In these situations, the GMO may seek additional information from the grantee and may make any necessary and appropriate adjustments.”
***Note:NIH policy is used as a representative example of Federal policy. All federal agencies have the same or very similar restrictions.
Examples of Expense Transfers
Expense transfers that may be appropriate:
-Correction of technical errors, such as data entry or transposition error
-Recurring and routine transfers to allocate direct expenses (if allowable), such as telephone charges, fuel charges and printing charges.
The methodology for allocating charges must be consistent, well-documented and based on the benefit derived.
Transfer of pre-award costs from another departmental account, given that the expenses
were allowable and allocable, and were incurred within the sponsor permitted time period before the beginning date of the award. Temporary accounts should be established for these types of pre-award costs if possible to avoid these types of expense transfers.
Transfers to move unallowable charges, or to eliminate a deficit, to a non-sponsored account
Expense transfers that are not appropriate:
-Transfers processed solely to move deficit spending from one sponsored project to another sponsored project
-Transfers that are processed solely to use up an unexpended balance, but do not appear to
be of direct benefit to the project, i.e. transfers of costs during the last months of a project
-Transfer of unidentified expense or lump-sum expenses to a sponsored project
-Transfers of expenses that were not incurred during the project period of performance, unless specifically allowed by the sponsor
-Transfer of Revenue, Cash, or Facilities & Administrative expense to or from a sponsored project
Last updated: 7/28/2020