Acceptance of Sponsored Program Awards and Fiscal Compliance on Sponsored Program Accounts (Budget Numbers)
UNIVERSITY OF WASHINGTON
Office of Sponsored Programs/Grant and Contract Accounting
GRANTS INFORMATION MEMORANDUM 2
Effective December 26, 2014
SUPERSEDES: GIM 2 (May 2, 2002)
This GIM is updated to conform to the Federal "Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards" (Uniform Guidance) effective December 26, 2014. This GIM applies to new awards and
new funding for existing awards received on or after Dec 26, 2014.
For awards in existence prior to December 26, 2014 that have not received supplemental funding or are not otherwise
subject to the Federal Uniform Guidance per sponsoring agency award terms and conditions, please refer to the
Archived GIM 2.
This GIM sets out the policy for acceptance of sponsored program funding and the fiscal management of sponsored
awards at the University of Washington, consistent with the Federal Uniform Guidance.
Sponsored programs are awarded to the University and not to individuals. Acceptance of external funding by the
University signifies the University's willingness to assume responsibility for the administration of the funds in
accordance with the terms specified by the sponsor, the applicable costing policy requirements, and other applicable
federal, state and local law and regulations. This responsibility is shared within the institution by the Principal
Investigator, the Chair and/or Director, the Dean, Office of Sponsored Programs, and the Grant and Contract
Accounting Office. All parties involved carry out processes to see that the terms of the award are observed, and
that expenditures during a given period are not in excess of funds awarded.
Principal Investigators, Research Personnel, Research Administration Personnel, Academic Unit Chair, Dean's Office,
eGC1 Reviewers, Office of Sponsored Programs, Grant and Contract Accounting, Management Accounting and Analysis,
Assistant Vice Provost for Research, Office of Planning and Budgeting.
All sponsored program awards are accepted on behalf of the University by the Office of Sponsored Programs (OSP) and
placed in sponsored program budget numbers by the Grant and Contract Accounting (GCA) office for administration by
the PI. Per UW Executive Order 34, OSP is
the only office with delegated authority to accept sponsored program awards on behalf of the University. All other
apparent or assumed authority to accept sponsored program funding is null and void.
Once accepted and made available in a sponsored program budget number, the Dean/Director, Chair and Principal
Investigator (PI) assumes the responsibility to oversee that appropriate internal controls are implemented to manage
the award at the project level. See the Procedures and Guidance section for guidance on
internal controls and signature delegation.
The University maintains internal controls over sponsored programs that provide reasonable assurance, at the entity
level, that the sponsored program is managed in compliance with applicable statutes, regulations, sponsor policies,
and the award term and conditions. Internal controls include centralized systems to support the administration of
sponsored program funding at the entity level, such as centralized receipt and acceptance of sponsored program
funding, appropriate budget number set-up, subrecipient monitoring, review and documentation of significant changes
that require sponsor approval or notification, as well as invoicing, draw-down processes, cash receipt, fiscal
reporting, and closeout. These systems are overseen by OSP and GCA.
The University reviews sponsored program activity and may recommend improvements, either through OSP, GCA or
Internal Audit. All instances of noncompliance are promptly acted upon and may involve reporting the instance to
the sponsor, require corrective action, termination of an award, inability for a PI to submit future proposals, or
return of funds.
GCA may require that the PI transfer expenditures or deficit from sponsored program budget numbers in order to
ensure that sponsor specific fiscal requirements are met and that the expenditures are consistent with the terms and
conditions of the sponsored agreement, federal, state or local law and regulations as well as University fiscal
The University has not budgeted separate funds for covering sponsored program deficits or disallowances. Deficits
and disallowances are administered in accordance with the
University Deficit Resolution Policy.
Procedures and Guidance
Methods of acceptance of an award
Budget number establishment
University fiscal policies that apply to sponsored programs
Restrictions on spending
Carryover of unobligated balances between budget periods and unexpended balances at end of project
Develops an over-all plan for the commitment and expenditure of grant and contract funds, working with the
authorized person(s) in the department, school , college or unit and consulting other University officers as
Initiates expenditures to be charged against the grant or contract account.
Supervises expenditure of sponsored program funds and approves subrecipient invoices (see GIM 8)to assure:
That funds are used only for purposes that directly relate to and benefit the activity supported in
That expenditures are consistent with all special terms, conditions, or limitations that apply to
expenditures under the particular grant or contract.
That expenditures do not exceed the total funds authorized for a given period under the grant or
contract. In many cases the grant or contract may also specify expenditure limits by budget category
or line item.
- Assumes accountability for deficits or disallowances that occur under a sponsored award.
Chair, Director, or Dean
- Establish systematic procedures in the college for supervision of grant and contract accounts.
- Provide reasonable coordinated administrative support for the management of grant or contract accounts.
Consult with principal investigator concerning the resolution of a deficit or disallowances incurred on a
grant or contract account and fix responsibility for settling the problem quickly.
Ensure that departmental personnel have access to on line financial systems for administration and
monitoring of financial activity.
Point of contact for OSP or GCA, when sponsor's questions related to expenses are associated with
performance of the scope of work.
Grant and Contract Accounting Office (GCA)
Provides principal investigator with information about any special terms, conditions, or limitations that
apply to each sponsored program account.
Consults on specific questions about the propriety of a given expenditure, on budget monitoring techniques,
and on other such matters.
Monitors certain types of sponsored program-related transactions on a sampling basis to assure consistency
with sponsor and University policies.
- Provides required fiscal reports and invoicing to sponsoring agencies.
- Receives and accounts for cash payments.
- Facilitates collection procedures through its aged receivable process
Office of Sponsored Programs (OSP)
- Reviews proposals consistent with GIM 1
- Accepts sponsored program funding on behalf of the University
- Prepares and approves Funding Actions in order to establish or supplement a sponsored program budget number
- Reviews requests to sponsors prepared by PIs, in which the PI is requesting prior sponsor approval
- Assists with notifying the PI regarding closing out a sponsored program
- Maintains sponsored program policies, including those regarding fiscal compliance, in coordination with GCA
Communicates with sponsors regarding changes that require amendments to current award criteria, scopes of
work, official requests for extensions and rebudgeting, or any other requests that are tantamount to a
change to the grant or contract.
Carries out entity level and project level risk assessment before issuing a subaward and monitors
subrecipients throughout the life of the subaward, on a periodic basis.
Is the contact office for disputes over contractual terms or performance on sponsored agreements, and will
escalate as needed.
Provides independent assurance to the Board of Regents and University management regarding the adequacy and
effectiveness of internal controls. This includes reviewing and evaluating:
Internal controls established to ensure compliance with applicable policies, plans, procedures,
laws, regulations, and contracts;
- The means with which assets are safeguarded;
- The reliability and integrity of financial and operating information;
- The economy, efficiency, and effectiveness with which resources are employed; and
- IT systems to determine if they are appropriately managed, controlled, and protected.
- Reports to University management on the areas examined.
- Evaluates management's plans or actions to correct reported findings.
Reports at least annually to the Board of Regents Finance and Asset Management Committee and to inform the
Board of any significant findings that have not been reasonably addressed by University management.
- Internal Controls:
A process designed to provide reasonable assurance regarding the achievement of the following objectives for
Transactions are properly recorded and accounted for, in order to:
- Permit the preparation of reliable financial statements and Federal reports;
- Maintain accountability over assets; and
- Demonstrate compliance with Federal statutes, regulations, and the terms and conditions of the award;
Transactions are executed in compliance with:
Federal statutes, regulations, and the terms and conditions of the award that could have a
direct and material effect on a sponsored program; and
Any other Federal statutes and regulations that are identified in the Audit Compliance
- Funds, property, and other assets are safeguarded against loss from unauthorized use or disposition.
- Sponsored program:
An exchange transaction between the University and the sponsor that is not a purchase or sale of goods or
services or "work for hire" arrangement but instead is a mutual exchange involving the University and a sponsor.
- Unliquidated obligation:
For financial reports prepared on a cash basis, obligations incurred by the non-Federal entity that have not
been paid (liquidated). For reports prepared on an accrual expenditure basis, these are obligations incurred by
the non-Federal entity for which an expenditure has not been recorded.
- Unobligated balance:
The amount of funds under a Federal award that the non-Federal entity has not obligated. The amount is computed
by subtracting the cumulative amount of the non-Federal entity's unliquidated obligations and expenditures of
funds under the Federal award from the cumulative amount of the funds that the Federal awarding agency or
pass-through entity authorized the non-Federal entity to obligate.
|Acceptance of Sponsored Program awards
|Budget number administration
|Responsible University Offices||Policy Owner|
|Office of Sponsored Programs and Grant and Contract Accounting
||Assistant Vice Provost for Research, as delegated by the Vice Provost for Research
This policy is reviewed by the Office of Sponsored Programs as necessary to reflect changes in Federal regulation
or University policies.