This GIM sets out the policy for acceptance and fiscal compliance of awards at the University of Washington (UW). There are also other GIMs that cover topics related to fiscal management of awards at the UW.
Awards are made to the UW and not to individuals. Acceptance by the UW signifies the UW’s willingness to assume responsibility for fiscal management of the award in accordance with the terms specified by the sponsor, applicable federal, state and local requirements, and UW policies.
Responsibilities for each of the following units or individuals:
Office of Sponsored Programs (OSP)
- Per UW Executive Order 34, all awards are accepted on behalf of the University by OSP. Acceptance of an award is made upon the signature of the OSP representative with delegated signature authority for the institutional official, acceptance of the award in a sponsor system by an appointed OSP user, or upon receipt or the processing of the award by OSP in UW systems.
- OSP is the only office with delegated authority to accept awards on behalf of the UW. All other apparent or assumed authority to accept awards is null and void.
- OSP reviews and submits requests to the sponsor where sponsor approval or notification is required.
- When necessary, OSP takes administrative actions on proposals and awards due to any issues that impact the stewardship of sponsored award funds or to adhere to sponsor policies.
Grant & Contract Accounting (GCA)
- Upon OSP acceptance of an award, GCA establishes an award and enters award information into UW financial systems.
- GCA informs the PI that the award has been established in the UW financial systems.
- GCA submits sponsor-required fiscal reports and invoices to the sponsor, unless an exception applies. Review more information on Reporting Your Award and Sponsor Payments.
- When necessary, GCA takes administrative actions on awards due to any issues that impact the stewardship of award funds and/or to adhere to sponsor policies. This includes suspending activities on the award in the UW financial system.
- The Dean/Department Chair is responsible for ensuring that appropriate internal controls have been established for all awards in their respective units.
- The Dean/Department Chair is responsible for ensuring that any corrective actions are taken by the PI.
- Provide reasonable coordinated administrative support for the management of sponsored awards.
- Resolution of a deficit or disallowances incurred on a sponsored award.
- Ensure that appropriate personnel have access to financial systems for administration and monitoring of financial activity.
- Work with OSP, GCA, Internal Audit and other UW units to resolve fiscal compliance issues.
The PI has the responsibility to ensure that funds are spent appropriately and in accordance with sponsor requirements, UW and Washington state policies, and cost principles. This includes:
Award Expenditure Approvals
- Supervises expenditure of sponsored program funds and approves subrecipient invoices.
- Expenditures itemized in the proposal and funded by the sponsor do not require additional approval by the PI.
- The PI is responsible for responding to any questions about the allowability of the cost on an award when questioned by OSP, GCA, and/or internal or external auditors.
Expenditure Approval Delegation
- PIs may provide documented delegation to conduct a variety of functions related to fiscal compliance on sponsored awards.
- Delegation should only be given to those who have direct knowledge of how the purchase benefits the award.
- The delegation of approval authority must be documented prior to initiating/approving the expenditure. The documented delegation must be maintained as part of documentation for the expenditure.
- Review delegation samples from Post Award Fiscal Compliance.
- Exception: Subaward invoice approval cannot be delegated.
Disallowed Costs & Deficit Resolution
- The PI is responsible for identifying a non-award funding source to allocate an award’s disallowed costs.
- Identification of disallowed costs or other instances of noncompliance may also result in the Dean/Department Chair, OSP, GCA or the sponsor:
- terminating or modifying the award;
- placing the award in a suspended status,
- restricting a PI’s future proposal submissions; and/or
- taking other administrative actions as necessary.
- If a deficit occurs on an award, the PI is required to follow the Grant & Contract Deficit Procedures.
The PI is responsible for ensuring adherence to the internal controls established by their unit for each award. This includes any additional or specific controls required by the sponsor, the Dean/Department Chair, or as necessary for completion of the award.
Effective internal controls should include procedures for establishing a control environment designed to promote a commitment to integrity, including, but not limited to:
- effectively sharing information and communication protocols;
- procedures to identify and assess risk of waste fraud and abuse;
- separation of duties for receipt and expenditure of funds;
- regular reconciliation of expenditures;
- delegation of authority for expenditure approval; and
- a system for evaluating the effectiveness of established internal controls.
This is in accordance with UW’s guide for Internal Control best practices.
Senior/Key personnel, as defined in GIM 10, are assumed to have approval for award expenditures. This can be overruled by written authority from the award PI.
UW Internal Audit
UW’s Internal Audit provides independent assurance to the Board of Regents and UW leadership regarding the adequacy and effectiveness of internal controls over compliance, information systems, fiscal management, and operations.
Other GIMs Related to Fiscal Compliance
The University maintains fiscal policies that guide the management of sponsored program funding. These policies include, but are not limited to, the following:
- Review and Submission Requirements for Proposals GIM 1
- Sponsored Awards: Acceptance and Fiscal Compliance GIM 2
- Fringe Benefit Rates and Sponsored Programs GIM 3
- Sponsored Program Subaward Administration GIM 7
- Subrecipient Monitoring GIM 8
- Advance Spending on Sponsored Awards GIM 9
- Facilities & Administrative (F&A) Rates GIM 13
- Accounting Adjustments on Sponsored Programs GIM 15
- Cost Share on Sponsored Awards GIM 21
- Sponsored Award Costing Policy GIM 23
- Effort Reporting for Sponsored Awards GIM 35
Details on changes to this GIM are available from the Office of Sponsored Programs, email@example.com