Post Award Compliance Checklist

Charges to budget must comply with University and Sponsor rules

  1. Charges posted to a grant:
    • Must be for goods and services rendered during the budget period that provide a direct benefit to the grant.
    • Must be approved by the PI or designee with direct knowledge of the needs of the project. See GIM 14
    • That are split between more than one grant must be split on the basis of proportional benefit or other reasonable method (not funding). See A-21 Cost Allocation.
    • Which are transferred to or from a grant must be properly approved and processed within 120 days of the original transaction.
    • Must have prior written approval from the sponsor on file within the department if the charges are not in the approved budget.
  2. Sponsored funds cannot be used as an interim funding source when awards are late. See GIM 9.
  3. Program Income must be identified and used in accordance with the terms of the award or federal regulations (OMB A-110). See Program Income Policies.
  4. Charges for items that are normally indirect (administrative and clerical salaries, office supplies, toner cartridges, flash drives, basic local telephone services, cellular phones, pagers and related service charges, routine copying charges, memberships, and journals and subscriptions) can only be charged directly to on-campus federal grants if in compliance with UW Cost Accounting Standards (CAS) policy and GIM 23.
  5. Charges that are not allowable per A-21 must not be charged to grants or contracts.

Additional resource from Internal Audit: Common Audit Recommendations

Reporting and Reconciling

  1. Review expenditures and supporting documentation, and resolve any discrepancies that are discovered. See Grant and Contract Closing Process.
  2. Notify GCA of pending charges or credits prior to the Final Action Date.
  3. Total expenditures must be compared to the budget on a periodic basis to identify any unplanned variances.
  4. Complete technical report and submit it by sponsor deadline.
  5. Complete property report and submit it by sponsor deadline.
  6. Complete invention report and submit it by sponsor deadline.

Documentation

  1. Faculty Effort Certification (FECs) must be certified online by the faculty member to reflect actual effort performed by the "Complete By Date" indicated on the FEC.
  2. Grant and Contract Certification Report of salaries must be reviewed for the appropriate assignment of salaries commensurate with the level of effort provided, then signed and retained in the department.
  3. Signature authority may be delegated in writing by the PI to those with direct knowledge of project in accordance with GIM 14.
  4. Mandatory cost sharing and committed cost sharing must be reported no less frequently than quarterly for the Non-FEC portion.
  5. Documentation in support of expenditures must be retained in accordance with the University Records Retention Policy.

Separation of duties

  • No one person can have complete control over all aspects of a financial transaction. Ideally, no single individual should be able to:
    --Authorize a transaction
    --Account for the transaction, and
    --Have custody of the asset relating to the transaction.
     
     

Additional information can be found on the Internal Controls website.

Learn more about specific areas of compliance by attending free courses offered by the Research Administration Learning Program.

References

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