university of pennsylvania sponsored projects compliance

University of Pennsylvania

Sponsored Projects Compliance Certification Program

Policies Related to the Administration of Sponsored Projects

University of Pennsylvania 2 Rev. 04/24/06

Sponsored Projects Compliance Certification Program

Welcome to the University of Pennsylvania’s Sponsored Projects Compliance Certification Program. The Program is designed to facilitate compliance with sponsored programs administrative requirements by addressing concepts critical to proper management.

This module examines the various University policies relevant to the administration of sponsored programs.



• Purpose:– To provide an overview of University policies critical to the

proper management of sponsored projects

• Coverage:– The presentation herein will provide an overview of

Sponsored Projects Policies and certain other financial policies; upon completion of the presentation, a link is provided to a knowledge test. Success in the test will depend on reading the policies in their totality


Policies Related to Sponsored Projects Activities

• Financial Policies– Sponsored Projects Policies– Procurement & Disbursement Policies– Travel & Entertainment Policies– Other

• Research Policies: Readers should be aware of and be able to refer to these policies in the conduct of research administration. These areas will not be tested in this module.– Conflict of Interest Policies– Misconduct in Research– Use of Human Subjects– Use of Animals– Environmental Health and Radiation Safety (EHRS) Policies– Intellectual Property (Patents, Copyrights, Trademarks, Research

Materials)


Sponsored Projects Policies Related to Pre-Award Activities

• SPP 2101 Administration of Sponsored Projects– All externally sponsored projects for research or other

purposes are administered through Research Services (ORS) in accordance with established University policies and procedures

• SPP 2102 Approval of Proposals– All proposal submissions, whether electronic or not,

seeking external support for research and other sponsored projects must be submitted to ORS for review and approval prior to submission



• SPP 2103 Administration of Clinical Trials– All externally funded clinical trials must be approved in

accordance with Policy No. 2102, as well as by the University’s Institutional Review Board, and performed under the terms of a formal clinical trial agreement which has been executed on behalf of the University by ORS

• SPP 2104 Negotiation of Awards– Ensures that the terms and conditions of agreements for

sponsored projects comply with established University policies and assigns authority for negotiations to ORS



• SPP 2109 Budgets– Places responsibility for preparation and submission of

sponsored project budgets on the Principal Investigator

• SPP 2136 Principal Investigator Eligibility– Establishes criteria permitting individuals to fulfill the role

of principal investigator or co-principal investigator on a sponsored project


Sponsored Projects Policies Related to Award Administration

• SPP 2105 Acceptance of Awards– Prior to any commitments, either formal or informal, agreements for

sponsored projects shall be reviewed and approved by ORS, and, when appropriate, the Office of the Vice President and General Counsel and/or the Center for Technology Transfer

• SPP 2106 Financial Responsibility– Places primary responsibility for the financial administration of

sponsored projects on the Principal Investigator

• SPP 2110 Direct Cost Expenditures– Establishes guidelines for the charging and approval of direct cost

expenditures on federal awards



• SPP 2111 Unallowable Costs– Establishes policy for the accounting of costs which are

unallowable charges against federally sponsored projects

• SPP 2112 Procurement of Goods & Services– Establishes responsibility for the procurement of goods and

services including subawards with sponsored project funds

• SPP 2113 Cost Transfers and Payroll Reallocations– Addresses the allowability and timeliness of transfers of

incurred costs, both payroll and other direct costs, to sponsored projects



• SPP 2114 Effort Reporting– Describes the University’s system of effort reporting in

compliance with Federal requirements

• SPP 2115 University Service Centers– Establishes policy to ensure compliance with Federal

regulations for accurately developing and costing service center charges to federally sponsored projects



• SPP 2131 Compliance With Subrecipient Standards of OMB Circular A-133– Establishes responsibility for compliance with the Office of

Management and Budget (“OMB”) Circular A-133 (Audits of States, Local Governments, and Non-Profit Organizations) as it relates to the University’s responsibilities in making awards to subrecipients

• SPP 2132 Record Retention– Establishes responsibility & timetables for the retention of

records, including documentation supporting project expenditures, in accordance with sponsors’ requirements



• SPP 2134 Expense Approval and Documentation Requirement– Describes required acceptable documentation indicating

approval for expenses charged to sponsored projects

• SPP 2135 Monitoring Subrecipients Not Subject to OMB Circular A-133– Establishes responsibility for monitoring subrecipients

receiving federal funds but not subject to the Office of Management and Budget’s (OMB) Circular A-133 (Audits of States, Local Governments, and Non-Profit Organizations)



• SPP 2138 Direct Cost Expenditures for Non-Federal Organizations– Establishes guidelines for the charging and approval of

expenditures on awards from non-federal sponsors which do not reimburse the University at the approved F&A rate

• SPP 2139 Faculty Summer Effort & Salary– Defines the requirements for faculty having appointments

less than 12 months who choose to work and receive full compensation from a sponsored project during the months of June, July and/or August


Procurement Policies Related to Award Administration

• Financial Policy Series 2300: Procurement & Disbursements Policies– Assign authority and responsibility for purchasing goods

and services

• Financial Policy 2312 Purchases of Laboratory Animals, Related Supplies & Equipment– Only University Laboratory Animal Resources is authorized

to purchase animals and related items

• Financial Policy 2313 Radioactive Materials– Approval from the Office of Environmental Health &

Radiation Safety Office is necessary prior to purchase radioactive materials


Procurement Policies Related to Award Administration

• Financial Policy 2319.1 Payment of Human Subject Fees– Establishes policy for the payment of human subject fees

• Financial Policy 2325 Gifts to Other Charitable Organizations– Describes situations under which the University may make

gifts to other charitable organizations


Other Policies Related to Award Administration

• Financial Policy Series 2350: Travel & Entertainment Policies– Provide guidelines and establish procedures for individuals

incurring business travel and entertainment expenses on behalf of the University

• Financial Policy 3001: Authority to Bind the University– Designates those individuals who may bind the University

under the authority of the Board of Trustees

• Financial Policy 3003: External Activities– Regulates the creation of new entities under the auspices of

the Board of Trustees


Sponsored Projects Policies Related to Cash Management & Financial Reporting

• SPP 2107 Accounting Authority & Responsibility– Assigns authority and responsibility for the accounting for

sponsored projects to ORS

• SPP 2108 Cost Accounting Standards (CAS)– Describes how costs must be accounted for and calculated

in order to ensure compliance with the Federal Cost Accounting Standards applicable to educational institutions

• SPP 2119 Cost Sharing/Matching Requirements– Establishes policy for the identification, funding,

accounting, and reporting of cost sharing or matching requirements in conjunction with a sponsored project



• SPP 2120 Accounting for Matching Gifts– Establishes accounting procedures to ensure compliance with financial

reporting and audit requirements under individual sponsored project agreements which stipulate matching gift requirements

• SPP 2121 Accounting for Program Income– Establishes accounting policy for program income earned on sponsored

projects. Certain sponsored projects generate income which, depending on sponsor regulations or the terms of the award, either is required to be remitted to the sponsor, or may be used as additional project support

• SPP 2122 Sponsored Project Payments– Designates ORS as having the sole authority and responsibility for the

deposit of cash received as payment on sponsored projects, and for the identification and posting of those payments to the appropriate sponsored project fund



• SPP 2123 Funding under Letter of Credit Agreements– Provides authority and responsibility for the request and maintenance of

letter of credit agreements funding sponsored programs to ORS

• SPP 2124 Direct Billing– ORS is responsible for issuing requests for advance payment, payment

by schedule, invoices, vouchers and any other financial instrument required to effect funding under sponsored project agreements. Exceptions to this responsibility must receive the prior approval of ORS in consultation with the Comptroller’s Office

• SPP 2125 Delinquent Payment/Nonpayment of Project Costs by Sponsors– Places responsibility for the resolution of delinquent payment and/or

nonpayment of project costs by sponsors on the Department and ORS



• SPP 2126 Interim & Final Financial Reports– Designates ORS as responsible for the preparation and submission of

interim and final financial reports required under sponsored project agreements. Authorizes ORS to determine allowability of costs

• SPP 2127 Sponsored Projects Close-out– Establishes responsibility for the orderly and timely close-out of

sponsored projects in accordance with sponsor requirements to include progress, invention, equipment and financial reports

• SPP 2128 Account Close-out– The principal investigator is responsible for all direct cost charges to the

sponsored project account and funds may not be obligated after the termination date of the sponsored agreement



• SPP 2129 Write-off of Overdrafts & Disallowances– Defines overdrafts & disallowances and assigns

responsibility to the responsible ORG for resolution

• SPP 2130 External Audits– Establishes responsibility for the coordination of external

audits, reviews, inquiries, and investigations of sponsored projects to ORS

• SPP 2133 Advances of Cash from External Sponsors– Establishes the appropriate accounting treatment of cash

advances from federal and non-federal sponsors under a sponsored project



• SPP 2137 Revised Final Financial Reports– Details the steps necessary to properly review and approve

the submission of revised final financial reports


Policies Related to Facilities & Administrative Costs

• SPP 2116 Facilities and Administrative (F&A) Costs– Establishes policy regarding the charging of F&A costs to

sponsored projects

• SPP 2117 Facilities and Administrative (F&A) Cost Rate Proposal Preparation – Assigns responsibility for the preparation of the F&A rate

proposal to ORS

• SPP 2118 Negotiation of F&A and Employee Benefit Rates– Assigns final responsibility for the negotiation of F&A rates

to the Vice President for Finance



• Congratulations!– You have finished reviewing the module on sponsored

projects policies– Please click here to access the quiz for this module

university of pennsylvania sponsored projects compliance

Documents

sponsored projects spp

research policies

sponsored projectrev

policies misconduct

sponsored project funds

ors spp

principal investigator

procedures spp