About Restricted Funds and Cost Analysis

The Restricted Funds and Cost Analysis Section of the Comptroller's Office performs the central University post award financial administration functions for all of the University's sponsored awards. It also prepares the indirect cost calculations required by federal regulations.

The Restricted Funds and Cost Analysis Section along with other sections of the Comptroller Office, Bursar's Office, and Central Procurement Services, develop and maintain the financial policies, procedures and systems that are needed in order to comply with the financial terms and conditions of sponsored awards.

The Restricted Funds and Cost Analysis Section is organized into three subsections: Post Award Administration, Accounting and Reimbursement, and Cost Analysis.

I. Post Award Administration

Post Award Administration maintains the central University financial records for each individual sponsored award. It is staffed with a Manager, four Post Award Administrators, and two Post Award Administrator Assistants.

The Manager is responsible for overseeing the activities of the Post Award Administrators staff and for coordinating audit activity as it relates to sponsored awards.

Each Post Award Administrator provides administrative and accounting support to the departments that are assigned to him or her. The Post Award Administrator is responsible for the award from the time an account is created for it in the Financial Accounting System (FAS) to the time the account is deleted from FAS.

The primary responsibilities of the Post Award Administrator are: 1) create or update FAS accounts for new and renewed award agreements; 2) provide financial compliance guidance to administrators and principal investigators; 3) approve cost transfers; 4) prepare financial status reports, 5) ensure budget overdrafts are resolved; and 6) closeout award FAS accounts.

FAS account creates/updates

There are several different processes for creating or updating and FAS account for a new award.  For  awards made to a unit administered by a Local Business Center (LBC) or certain other departments, the LBC or department will create/update the account. For other units, Restricted Funds creates/updates the account. Restricted Funds creates an account for a new award upon receipt from University Research Administration (URA) of an approved Form 70 (Request for A Restricted Fund Account . Ledgers 5 and 6) or an electronic NIH/NSF Notice of Grant Award (NGA). In the case of the electronic NIH/NSF NGA, Restricted Funds matches the NGA with a generic Form 70 it has on file for the department that "owns" the award. Restricted Funds will update an account for a renewal award upon receipt of the renewal NGA from URA.

In addition, to the account create processes described above, FAS accounts can be created in advance of receipt of an NGA if approved by URA. These accounts are referred to as advance accounts.

Financial compliance guidance

Restricted Funds provides guidance to administrators and principal investigators on how to comply with a sponsored award's financial terms and conditions. Important University guidance is available at several University and non-University Web sites. Sites that Restricted Funds frequently refers people to include the following:

Cost transfers

Restricted funds reviews cost transfers to ensure that they are in compliance with the University's Cost Transfer Procedures for Sponsored Project Accounts.

Financial status reports

Almost all sponsoring agencies require a Financial Status Report (FSR) at the end of the award, but some also require interim FSRs. Restricted Funds is responsible for seeing that the FSRs are submitted to the sponsoring agency. FSRs not submitted timely may result in the sponsoring agency withholding payments and/or suspending future award activity for all University principal investigators.

In some cases, Restricted Funds can prepare an FSR from the University's AM090, 91 Accounting Reports. However, in most cases the AM090, 91 Accounting Reports have to be augmented with trailing transaction information (i.e., expenditure charges or credits that have not yet been posted to FAS).

In those cases where the AM090, 91 Accounting Report information has to be augmented, Restricted Funds will notify the Account Administrator No. 1 approximately 45 days prior to the FSR period end date that a FSR is due. The Restricted Funds notice will request that the trailing transactions be itemized on the Closing Memo Worksheet that is attached to the notice and that the Closing Memo Worksheet and supporting documentation be returned to Restricted Funds at least 15 days prior to the FSR due date.

In a few cases, the FSR requires such detailed reporting that the Account Administrator No. 1 must complete it. In these cases, the Account Administrator No. 1 must provided Restricted Funds with a reconciliation of the FSR to the AM090, 91 Accounting Reports. Upon Restricted Funds approval of the reconciliation, the FSR is submitted to the sponsoring agency.

Budget overdrafts

Allowable budget overdrafts can occur for a numbers of reasons: costs may be mistakenly charged to an account, the account may be an advance account, expenses may be charged in advance of a non-competing renewal award causing a temporary budget overdraft, etc. These overdrafts are resolved by correcting an accounting entry or by the receipt of new or additional award authority from the sponsor.

An unallowable budget overdraft is an overdraft that is caused by a cost overrun. These overdrafts must be removed as soon as it is learned that there will be no additional sponsor funds to cover the cost overrun. If the award administrator fails to remove the overdraft in a timely manner, Restricted Funds may charge the overdraft to the guarantee account indicated on the award's Form 70.

Closeout award FAS accounts

Restricted Funds is responsible for closing sponsored award accounts in FAS. The process is as follows:

  • An account is closed out when project-to-date expenses in FAS agrees with the total expense reported on the FSR, all funds have been received from the sponsor, and all payables have been paid.
  • If an account is overspent, the award administrator must remove the overdraft in order for the FAS account to be closed.
  • If an account is underspent, and reported as such on the FSR, Restricted funds will adjust the account budget to equal the expenses reported on the FSR before closing the account.
  • The amount reported on the FSR may not equal the expenses shown in the FAS account at the time the FSR is submitted because of trailing transactions that have not yet been posted to FAS. The FAS account cannot be closed until the trailing transactions are posted. The award administrator must continue to monitor the account activity to ensure that the trailing charges are posted.
  • When the budget equals the project-to-date expenses on FAS, all funds have been received from the sponsor, and all payables have been paid, then Restricted Funds will delete the account from FAS and AM090, 91 Accounting Reports will cease.

Audits

Restricted Funds is responsible for the coordination of all sponsored award audits. If an award administrator or principal investigator is contacted directly by an auditor, they should refer him or her to the Manager of Post Award Administration.

Restricted Funds will provide to auditors source documentation for payroll and non-payroll disbursements and many other transactions. For some transactions, however, a recharge center or the department in which the award is performed may be called upon to provide additional documentation.

Restricted Funds will coordinate the University response to any preliminary or final audit finding.

II. Accounting and Reimbursement

Accounting and Reimbursement's primary responsibility is to ensure that the University receives all of the funds due from sponsoring agencies. The Section is staffed with a two accountants. Its core activities include: 1) drawing down cash form letter-of-credit agreements; 2) invoicing sponsors; 3) completing cash reports required by federal sponsors, and 4) resolving sponsored award account receivable issues.

In most cases where an award requires an invoice, Accounting and Reimbursement will prepare the invoice. Most of those invoices are prepared directly from the AM090, 91 Accounting Reports on a monthly or quarterly basis. In those cases where the invoice requires more information than can be obtained from the AM090, 91 reports, the department, with Accounting and Reimbursement's approval, will prepare the invoice. Once the department completes the invoice, they submit it and its reconciliation to AM090, 91 reports to Accounting and Reimbursement for their approval. Once Accounting and Reimbursement approves the invoice, the department or Accounting and Reimbursement submits the report to the sponsoring agency.

III. Cost Analysis

The Cost Analysis Section's prime responsibility is to calculate the University's indirect cost rate in accordance with OMB Circular No. A-21 regulations. The responsibility entails collecting, analyzing, and managing data from multiple sources: Space Inventory System, Property Management System, Payroll System, and the Financial Accounting System. The Section is staffed with a manager and one accountant.

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