Grants & Contracts Accounting
Grants & Contracts Accounting jbarber32Allowable Expenses
Allowable ExpensesThe purpose of this policy is to describe the different types of costs incurred by an institution and to identify which costs are allowable versus unallowable on sponsored programs. Unallowable costs are not eligible for reimbursement by the sponsor and must be covered on non-sponsored funds. Policies and procedures developed by the Office of Grants and Contracts Accounting are based on the Federal government’s Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR Part 200) Subpart E “Cost Principles”. Individual sponsored awards may contain terms and conditions that are more specific and that are either more or less restrictive than 2 CFR Part 200 Subpart E. In these cases, the individual award/agreement will be used to determine the allowability of expenses posted directly to the associated sponsored award(s). In all cases, expenses must be accounted for in accordance with applicable Georgia Tech operating procedures.
From OMB 2 CFR Part 200.403: The factors affecting allowability of costs under these principles are:
- They must be necessary, reasonable, and allocable;
- They must conform to any limitations or exclusions set forth in the principles or in the Federal award as to types or amount of cost items;
- They must be consistent with policies and procedures that apply uniformly to both Federally-financed and other activities of the non-Federal entity;
- They must be accorded consistent treatment as either a direct or indirect cost;
- They must be determined in accordance with generally accepted accounting principles (GAAP);
- They must not be included or used to meet cost sharing or matching requirements of any other Federally-financed program; and
- They must be adequately documented
If any activity/expense cannot meet the above criteria, it may not be charged directly or indirectly to a sponsored project, regardless of its purpose.
Below is a list of costs normally considered unallowable. This is not an all-inclusive list, and, depending on the project scope and the sponsor specific agreement, some costs that are generally unallowable may be allowable for a specific project.
- Office supplies
- Telephone toll charges / hand-held communications device charges
- Administrative or clerical salaries*
- Postage
- First Class or Business Class travel
- Entertainment, including alcohol
* Salaries of administrative and clerical staff may be charged directly only if all of the following conditions are met:
- They are integral to the award or activity;
- Individuals involved can be specifically identified with the award or activity;
- Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and
- The costs are not also recovered as indirect (F&A) costs.
The following expense types are typically allowable as a direct charge to a sponsored award (2 CFR Part 200.453):
In the specific case of computing devices, charging as direct costs is allowable for devices that are essential and allocable, but not solely dedicated, to the performance of a Federal award.
Certain non-sponsored expenses may be unallowable for inclusion in the F&A Cost reimbursement rate, which is applied to eligible direct expenses on sponsored funds. Examples include fines/penalties, commencement expenses, and fund-raising activities. Unique ledger account or worktags are used to identify unallowable activities.
This policy applies to all Georgia Tech Faculty and Staff engaged in Resident Instruction research or administration of Resident Instruction research.
Allocable
…the goods or services involved are chargeable or assignable to that award in accordance with relative benefits received (200.405)
Allowable
...conforms to limitations or exclusions set forth in the sponsored agreement and these principles as to types or amounts of cost items
Consistently Treated
…may not be charged as a direct cost if any other like cost has been allocated or charged as an indirect cost (200.403)
Direct Charges
Charges on awards are allowable if they can be identified specifically to or associated with a particular sponsored project and are not treated as a facility or administrative (F&A) cost item.
F&A Costs
F&A cost items are incurred for common purposes, such as office supplies, departmental administration, facility costs, and general purpose equipment that are charged to sponsored awards via the appropriate F&A cost reimbursement rate.
Reasonable
... does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost (200.404)
Georgia Tech authorizes the principal investigator (PI) and the properly authorized unit designee (financial manager and staff) to have primary responsibility for the management of sponsored agreement funds. It is the responsibility of PIs, unit heads and staff delegated signature authority by unit heads to ensure that only allowable charges are posted as direct expenses to sponsored awards. Unit financial managers have the most up-to-date information regarding compliance with allowable expenses on sponsored awards. As noted earlier, units are also responsible for covering unallowable expenses that cannot be charged either directly or indirectly to sponsored funds. Local management’s approval of a financial transaction indicates:
- Goods or services are directly related to the award scope
- Charges are allowable according to the approved award budget
- Charges have been incurred within the award time period
- Charges have been incurred in accordance with Georgia Tech financial and accounting policies and procedures
- Charges have been incurred in accordance with Terms and Conditions of the sponsored agreement
- Funds are available in the designated awards
| Revision Date | Author | Description |
|---|---|---|
| 5-20-2024 | Office of Grants and Contracts Accounting | Editorial updates to remove procedural guidance from the policy. |
| 12-26-2014 | Office of Grants and Contracts Accounting | Update to conform to Office of Management and Budget Uniform Requirements issued 12-26-2013 |
Cost / Service Centers
Cost / Service CentersService centers are defined as operating units established for the primary purpose of providing specialized service to the educational and research community. Service centers are also known as Specialized Service Facilities and are subject to the terms and conditions of OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR 200), Section 200.468.
This cost accounting policy is based on OMB Uniform Administrative Requirements, Section 200.468 (2 CFR 200) which states: "The costs of such services, when material, must be charged directly to applicable awards based on actual usage of the services on the basis of a schedule of rates or established methodology".
This policy is applicable to all Cost/Service Centers established at the Institute.
|
Specialized Service Facilities (SSF) |
Operating units which provide specialized services to the university community, with annual operating budgets in excess of $1,000,000 annually or based on management discretion. Additional procedures related to Service Center rate studies are included below. |
|
Service Centers |
Operations with greater than $5,000 in operating expenses annually or any charges to sponsored projects regardless of size where the business-case for establishing a separate service center has been properly justified and is approved in advance by the Sr. Director of Grants and Contracts Accounting and the appropriate College or Institute level officer. Costs for materials/services should constitute a pass-through of direct costs only. Service centers should be able to demonstrate that there is an advantage to the sponsor to justify its existence. Grants and Contracts Accounting is available to provide assistance in developing such pass-through rates. |
| Facility Usage Rates | Rates established with a defined time period for the infrequent and non-recurring use by external entities of Georgia Tech lab facilities that are unique and not commercially available. Grants and Contracts Accounting will develop the appropriate Facility Usage rates in coordination with the requesting department. |
Basic Requirements
Due to the administrative requirements of managing service centers, there should be a clear business-case for establishing and renewing separate service center charge rates. The requisite business-case includes the following basic parameters:
- Self-Supporting Revenues - Service center annual recoveries should typically be sufficient to fund the annual operating costs of the center. Any cost in excess of revenue should be posted to a discrete project so total center costs can be easily identified. Direct costs include allocable salaries, fringe benefits, supplies, equipment maintenance, and maintenance agreements. SSFs also include indirect costs such as building depreciation, equipment depreciation, and building operations and maintenance expenses (including utilities).
- Local Administrative and Financial Support - The unit/department must be equipped to manage the additional accounting and reporting requirements of the Center. These activities include separate accounting for expenses and recoveries and precise tracking of utilization for charge-out purposes.
- College and Institute Level Approval - The “Service Center Rate Study Request” form must be completed and approved by the appropriate School or Department Head and the appropriate College or Institute level officer prior to being submitted to Grants and Contracts Accounting for consideration. The form can be found on the Grants and Contracts website.
Service/recharge center rates may only be established or renewed after the above basic requirements have been met, documented, and properly approved. Thereafter, rate studies are prepared and billing rates are established and renewed based on the following procedures:
Service Center Rate Studies and Billing Rates
- Proposed billing rate studies are scheduled on an annual basis. Estimated rate calculations will be developed based on the most recent completed fiscal year. Estimated rate calculations for Resident Instruction and Units other than GTRI are to be submitted to Grants and Contracts Accounting annually. Rates normally become effective July 1 of the subsequent year. Prior to ONR approval, if required, rates utilized will be considered provisional until subsequently amended.
- Billing rates may not be based on what others charge for similar services.
- Service rates should include both direct and for SSFs an allocable share of Facilities & Administrative (F&A or indirect) costs. The proposal should consist of prior year historical costs all equipment depreciation costs by specific item, net square footage occupied and any over/under recovery from the prior year if required. The proposal should also contain documented utilization of the cost center from the prior period and a justification of the selected utilization base.
- All billings are to be invoiced to a Georgia Tech account/project. Direct expenses applicable to the service center and all offsetting billing revenues should be recorded to worktags established for purposes of reporting and accounting for center activities.
- Agreements to conduct services for external entities may be evaluated by the Office of Sponsored Programs (OSP) and should be based on the OSP short form contract document. Billings to external parties are coordinated through the Bursar’s Office after approval is gained via Grants and Contracts.
- Service Center rates are validated periodically to ensure that charge rates were at or below cost during the prior period(s). This validation work is scheduled and managed by the Grants and Contracts Accounting Office with significant assistance from the responsible Center or Unit Financial Officer. Accurate tracking and reporting (including detailed supporting documentation) for expenses and revenue entries is critical to the timely performance of service center rate studies and validations.
- Existing (previously approved) service centers that do not meet the basic "business-case" requirements noted above will be reevaluated as part of the annual rate validation step. In these cases, Service Center billing rates may be suspended or lapsed until the business-case is reestablished and properly approved via the "Service Center Rate Study Request” form. Grants and Contracts Accounting will notify the responsible Institute, School, Center, and Unit contacts at least 30 days prior to this action.
- Existing (previously approved) Service Center billing rates where a significant amount of charges were posted to sponsored projects will be suspended if this validation and renewal process is not completed in a timely fashion. Grants and Contracts Accounting will notify the responsible Institute, School, Center, and Unit contacts at least 30 days prior to this action.
- Existing (previously approved) service centers with costs posted to a non-DSS project will require College or Institute level officer approval of support annually.
Service center rates that are not documented, supported, validated, and renewed in accordance with this policy may not be charged to externally-funded sponsored projects.
Contact the Grants and Contracts Accounting Department at gc.ask@business.gatech.edu for additional guidance related to Cost/Service Centers at Georgia Tech.
To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at:
https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508
| Revision Date | Author | Description |
|---|---|---|
| 09-20-2021 | Office of Grants & Contracts Accounting | Editorial Updates to align with Workday implementation. |
| 04-2015 | Office of Grants & Contracts Accounting | Update with new OMB Requirements |
| 12-30-14 | Office of Grants & Contracts Accounting | Align with requirements of 2 CFR 200 |
| 07-01-12 | Office of Grants & Contracts Accounting | Administrative review |
Cost Share
Cost Share jbarber32Cost Sharing Policy
Cost Sharing PolicyGeorgia Tech may provide cost share for projects funded by U.S. state, local or federal government agencies or non-profit organizations. This policy provides guidance for assessing, managing, and obtaining required approvals for such commitments in order to protect the Institute and the researchers engaging in the work, and to allow for consistent reporting to external sponsors.
All researchers who engage in sponsored or externally funded research will comply with Institute and sponsoring agency policies as well as any applicable regulations regarding cost sharing requirements on all proposals and awards.
All Cost Sharing
The commitment of funds for cost sharing is subject to the availability of funds for that purpose.
Cost share commitments must be approved prior to proposal submission by units that are contributing the funds. In addition, the Office of the EVPR must review all proposed voluntary committed cost share.
Mandatory and Voluntary Committed Cost Sharing Contributions are auditable and are allowable only when they meet all the following criteria:
- Are verifiable from the recipient's records.
- Would be allowable as a direct cost on the grant.
- Are not included as contributions for any other federally assisted project or program.
- Are necessary and reasonable for proper and efficient accomplishment of project or program objectives.
- Are allowable under the applicable cost principles.
- Are not paid by the Federal Government under another award, except where authorized by Federal statute to be used for cost sharing or matching.
- Are provided for in the approved budget when required by the Federal awarding agency.
- Conform to provisions of 2 CFR 200 or other sponsor requirements, as applicable.
Voluntary Uncommitted Cost Sharing
Any funding or other resources needed for voluntary uncommitted cost sharing should be approved prior to proposal submission to the funding entity.
Third-Party Cost Sharing
Funds to be provided by entities outside of Georgia Tech must be supported at the proposal stage by written documentation from an authorized official at the outside entity indicating its commitment to provide cost sharing.
If the third-party entity fails to fulfill its cost sharing obligation, the lead PI’s unit is responsible for covering the commitment.
This policy applies to all Georgia Tech faculty and staff engaged in, administering, or overseeing research.
Approver
Individual authorized by the unit to oversee respective unit budgets.
Cost Sharing
The part of project or program costs not borne by the funding agency but supported by contributions from the recipient and/or third parties. Cost share items may include but are not limited to matching funds, faculty effort, financial support for project activities, and other contributions of university resources and services. Cost share may be mandatory or voluntary.
Mandatory Cost Sharing
Contribution required by the sponsor as a condition of receiving an award. Principal Page 3 of 5 investigators must include the total amount of the cost share commitment in the proposal budget.
Principal Investigator (PI)
Lead researcher on a sponsored project. Learn more about PI/PD eligibility here.
Third-party Cost Sharing
Contribution provided by entities outside of Georgia Tech.
Voluntary Committed Cost Sharing
Contribution that is not required by the sponsor but included in the proposal budget, creating a binding commitment equal to that of mandatory cost share. Voluntary Committed Cost Share is often prohibited by sponsors and is rarely appropriate. An example of permitted voluntary committed cost share is where it is allowed by the sponsor and listed as a review criterion.
Voluntary Uncommitted Cost Sharing and Other Support
Faculty or senior researcher effort that is over and above that which is committed and budgeted for in a sponsored agreement and unquantified descriptions of cost sharing in sections of the proposal other than the budget or budget justification, such as Facilities, Equipment and Other Resources or Other Support.
All Cost Sharing
Documentation
Approvals for cost sharing of any kind are documented in Institute-level systems such as GT-TRACS and eRouting to ensure clarity and accessibility for all stakeholders.
Principal Investigator
Obtains approval prior to proposal submission from units that are contributing the funds. Learn more about PI/PD eligibility here.
Office of the Executive Vice President for Research Approves all cost share at the institute level and voluntary committed cost share from any unit.
Office of Sponsored Programs
Confirms that all necessary cost share documentation is in place at the proposal stage.
Associate Deans for Research
Facilitate cost share conversations and processes at the college level.
Units
Appoint an appropriate approver with financial oversight for all cost share requests.
Approver
Ensures that adequate funding exists to support the cost share request and is authorized by the unit to commit the funds. This person is identified within GT-TRACS.
If a PI submits a proposal without obtaining approval for committed cost share, the Institute may be forced to decline the award. After a project is awarded, consequences for non-compliance with cost share commitments are typically determined by the sponsor but may include Georgia Tech or sponsor termination or freeze on the account and may result in disciplinary action by the Institute where appropriate.
Cost Share Expenses
Cost Share ExpensesCost share (Matching) funds are those funds contractually obligated by the Institute to meet the financial requirements specified in a sponsored award. These expenses represent the Institute’s contribution to an externally funded sponsored project. When a cost share obligation is identified in the sponsored agreement, it must be accounted for in the Institute’s accounting records and reported to the sponsor. Cost share expenses should generally be incurred at the same rate as the sponsor’s portion of award expenses.
The Federal Government’s Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR 200 – 200.306 “Cost sharing or matching”) indicates that all contributions, including cash and third party in-kind contributions, must be accepted as part of the recipient's cost sharing or matching when such contributions meet all of the following criteria:
- Are verifiable from the recipient's records.
- Are not included as contributions for any other Federal award.
- Are necessary and reasonable for accomplishment of project or program objectives.
- Are allowable under Subpart E – Cost Principles.
- Are not paid by the Federal Government under another award, except where authorized by Federal statute to be used for cost sharing or matching.
- Are provided for in the approved budget when required by the Federal awarding agency.
- Conform to other provisions of this Part, as applicable.
If any expense cannot meet the above criteria, it is not eligible to be recorded and reported as cost share. In addition to expenses incurred by Georgia Tech, the following types of expenses may be counted as cost sharing if properly approved, documented, and supported:
- Unrecovered F&A (indirect) costs, including indirect costs on cost sharing or matching, with the prior approval of the Federal awarding agency based on approved rates.
- Unrecovered tuition remission costs with the prior approval of the Federal awarding agency based on approved rates.
- Donated supplies, equipment, or property based on current fair-market values and period-of-use requirements [reference 200.434 “Contributions and donations”].
- Third party contributions of personal services, supplies, equipment, property based on current fair-market value and period-of-use requirements [reference 200.434 “Contributions and donations”].
Generally speaking, only expenses that would be allowable to the sponsored project are allowable as cost sharing expenses. Any exceptions to this rule must be approved and documented (i.e., salaries in excess of the NIH salary cap or waived Tuition Remission expenses).
All employees engaging in sponsored research activity.
Unrecovered F&A
The difference between the amount charged to the Federal award and the amount which could have been charged to the Federal award under the recipient’s approved negotiated indirect cost rate.
Internal Institutional support
Internal institutional funding provided to the unit upon successful receipt of a research award, which is not contractually obligated by the sponsored program.
The GM System obtains contract information directly from the OSP database. Since all projects with Cost Sharing requirements must be managed by OSP, the GM System receives all authorized Cost Share/Matching information at the time of the award or any subsequent amendment. Upon completion of an agreement by OSP, Project Numbers are assigned. If there is a contractual Cost Sharing requirement a Cost Sharing Project number will be assigned.
The amount of the Cost Sharing requirement is entered into the Project Demographic section of the GM Project files. Cost Share budgets are entered by the departments via the Institute budgeting process into the Institute’s General Ledger System. These budget amounts are subsequently added to the GM project files systematically. The budgets in the GL System will only reflect the amount of funds budgeted by the departments.
The Grants Management (GM) System allows for all companion cost share projects to be linked, summarized, and reported in accordance with applicable requirements. For this reason, all cost share projects should be associated with the appropriate sponsored award/fund within the GM system.
The GM System reports Cost Share Obligation on the "Fund" Demographics Panel. The amount of the budget to be reflected in the cost share project(s) is to represent the funded amount available to spend (plus amounts already expended). A comparison of the total amount budgeted (including State funded cost sharing and GTRC funded projects) to the obligation will indicate the amount of additional funding required.
All related cost share projects are linked to the sponsored project for reporting purposes. Additional companion Cost Share projects may be established by appropriate personnel throughout the life of a sponsored project to properly account for all applicable cost sharing expenditures. When this occurs, the Office of Grants and Contracts Accounting should be notified immediately in order to ensure proper set-up in the GM System.
Projects should not be set up or allocated in the accounting records as cost share projects unless they are contractually required by the sponsor. Internal institutional support that is necessary but not contractually required should be set up by the Budget Office as other State funds outside of the matching fund group of sponsored projects.
Cost Share Documentation Requiring Special Certification and Approval Authorization
On an exception basis, cost share expenses posted to non-companion discretionary projects may be recorded as cost sharing for the applicable sponsored award. In these cases, the Principal Investigator and appropriate unit financial officer are required to complete the cost share certification form, which certifies the project can be used as matching contribution. Source accounting system support and pertinent summary schedules must accompany this certification page.
Documentation and certification of prior fiscal year cost share expenses posted to “non-companion” projects must be approved by the Director of Project Accounting or Senior Director of Grants and Contracts Accounting prior to processing. Requests that exceed 120 days of the initial posting date will follow the Late Cost Transfer process for review and approval.
Federal Salary Limitations (NIH Salary Cap)
The Cost Sharing accounting mechanism referenced above should be used to account for salary limitations applicable to NIH grant and cooperative agreement awards and extramural research and development contract awards. In so doing, the appropriate amount of effort devoted to the NIH award is visible in the accounting records of the Institute.
Refer to the G&C website for Frequently Asked Questions related to cost sharing.
http://grants.gatech.edu/main/wp-content/uploads/2014/03/FINAL_Cost-share-FAQ_1.pdf
Contact the Office of Grants and Contracts Accounting at gc.ask@business.gatech.edu for additional guidance related to sponsored cost transfer requests.
Principal Investigators, assigned delegates, and unit financial officers are responsible for providing proper oversight and management of sponsored projects during the performance and close-out periods.
To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508
| Revision Date | Author | Description |
|---|---|---|
| 11-05-2014 | Office of Grants & Contracts Accounting | Align with requirements of 2 CFR 200 |
| 04-01-2014 | Office of Grants & Contracts Accounting | Administrative review |
Cost Transfer Requests
Cost Transfer RequestsCost transfers are a sensitive issue in a university's operation of its sponsored programs and one which always receives careful scrutiny by sponsors. Accordingly, the following policy has been established to ensure full compliance with federal regulations, contract and grant terms and other conditions concerning cost transfers for Resident Instruction (RI), Georgia Tech Professional Education (GTPE), and Enterprise Innovation Institute (EII) programs. The Georgia Tech Research Institute (GTRI) has a separate policy in place that is applicable to its projects.
Cost Transfers that are required to correct errors or to achieve the proper, consistent, and equitable distribution of costs to sponsored projects will be allowed, provided adequate justification for the change is furnished by the requesting unit and necessary approvals that certify the accuracy of the charges are received by Commitment Accounting and Grants and Contracts Accounting. Such Cost Transfers should be made as soon as possible after the necessity for the transfer is recognized. A Cost Transfer made within 90 days after the posting date of the transaction will be considered timely. In exceptional instances, Cost Transfers may be required after the 90-day period. In such situations, it is acceptable to process a Cost Transfer beyond the 90-day limit if the Cost Transfer request is properly supported and certified, and adequate documentation is provided (see Non-Personal Service Cost Transfers Requiring Special Approval Authorization below). This policy is applicable to Non-Personal Service Cost Transfers. See Policy 3.2 “Personal Services Reporting Using the Plan Confirmation System” for specific procedures related to retroactive salary distribution changes.
Non-Personal Service Cost Transfers
Georgia Tech authorizes the principal investigator (PI) and the unit designee (financial manager and staff) to have primary responsibility for the management of sponsored agreement funds. Requests for a non-personal service Cost Transfer should originate with the unit that originally approved the charge. The request will require adequate supporting statements that clearly indicate that the costs being moved to sponsored worktag are directly related to the project scope, allowable by the project budget, and incurred in a timely manner such that they benefit project activities. The designated financial administrator or other responsible party with firsthand knowledge, according to delegated authority within the unit, must review the Cost Transfer for accuracy and appropriateness.
Cost Transfer Request
A request for a non-personal service Cost Transfer involving sponsored awards must be submitted by the appropriate unit personnel in accordance with Institute procedures. All requests must be approved by at least two authorized employees, unless the request involves moving costs from sponsored onto non-sponsored funds or the transfer is performed by central administration accounting staff. In these instances only one authorized approver is needed. The approval may also only require one approval if an authorized approver initiated the change, or the department has the same person serving in multiple roles in the workflow framework. Some requests will require additional approval based upon established validations.
Non-Personal Service Cost Transfers Requiring Special Documentation
For every cost transfer, a valid and complete explanation is required that clearly indicates that the costs being moved to a project are directly related to the project scope, are allowable by the project budget, are allowable by the terms and conditions of the award, and are required to complete the objectives of the sponsored agreement. In addition, any available supporting documentation should be attached to the Cost Transfer Request so that it will be available for subsequent audit review. At a minimum, supporting documentation means that a copy of some form of original documentation (such as a travel expense report, original invoice, etc.) will be provided. Const transfers performed by central staff to move charges to a cost overrun worktag do not require an additional explanation. These transfers are based on reviews by central staff and are normally performed to eliminate budget overruns or charges outside the period of performance.
Cost Transfers onto sponsored worktags are not acceptable under the following circumstances:
- To correct deficiencies caused by overruns;
- To avoid restrictions imposed by law or by the terms/conditions of the sponsored award;
- To temporarily place charges which will subsequently be transferred elsewhere.
In addition, costs may not be transferred to a sponsored project merely because there are unexpended funds available that would otherwise be returnable to the sponsor.
All Cost Transfers are to be processed in a timely manner and properly documented. Cost Transfers to externally-funded** sponsored awards beyond 90 days of the original expense posting will not be allowed under normal circumstances unless performed by central staff during closeout.
There are certain circumstances where exceptions to this policy may be warranted. Under these circumstances, consideration for recognition of Cost Transfers beyond 90 days will be addressed by the Grants & Contracts Accounting Office. Examples of Cost Transfer situations that represent allowable exception requests can be found on the Grants and Contracts website.
If the transfer is requested within the reporting period of the sponsored project (which typically ends 60-90 days after the expiration date of the project) and the terms and conditions of the sponsored agreement provide for acceptance and payment of the expenses covered by the proposed Cost Transfer and appropriate supporting documentation is provided, the Director or Executive Director of Grants & Contracts Accounting or their designee may approve the proposed transfer. Other exceptions will be considered on a case-by-case basis.
** Excludes sponsored projects funded by the Georgia Tech Foundation and Georgia Tech Research Corporation. Transfers between projects associated with the same sponsored fund (award) are not subject to the 90 day limitation.
All employees engaging in sponsored research activity.
Cost Transfer
A Cost Transfer involves an action in which costs are moved from a non-sponsored worktag to a sponsored award or from a sponsored award to another sponsored worktag. Excluded are initial transfers of charges for supplies or services from an inventory account, a cost center, or other similar operations in accordance with established accounting procedures. Also excluded are corrections of processing errors that occur within the Business Office of Finance and Planning accounting systems such that when the correction is made, the accounting records are in agreement with the documentation that authorized the change. Corrections of encumbrances are not considered Cost Transfers, and any such changes are to be processed according to Procurement and Business Services Office procedures.
Forms
Non-personal service cost transfers can be initiated in the units via a journal entry or accounting adjustment in Workday. To obtain hard copy forms for prior year salary cost transfers, please contact the Office of Grants & Contracts Accounting at gc.ask@business.gatech.edu or go to https://grants.gatech.edu/.
Frequently Asked Questions
Contact the Office of Grants and Contracts Accounting at gc.ask@business.gatech.edu for additional guidance related to Cost Transfer requests.
Principal Investigator (PI) Responsibilities
Each Georgia Tech PI is responsible for effectively overseeing and managing their sponsored projects based upon their knowledge of the field of study and their capabilities to conduct the projects in an efficient and productive manner. PIs are to perform periodic reviews of charges to provide proper financial oversight as outlined in the PI Project Management Reference Manual.
Authorized Unit Designee (financial manager, grant manager and staff) Responsibilities
Each Georgia Tech research administrator is responsible for effectively overseeing and managing sponsored award portfolios based upon their knowledge of award terms and conditions and applicable federal, state, and institutional policies and procedures. Unit Designees are also responsible for the accuracy, allowability and allocability of charges authorized by the PI or their designee and providing adequate documentation in a timely manner.
Grants & Contracts Accounting Responsibilities
The Grants & Contracts Accounting Office approves Cost Transfers meeting approval criteria based on review of the proper authorization, accuracy of the accounting, and adequacy of the supporting documentation in accordance with federal, state, and institutional policies. Reliance is placed upon the submitting unit, as the level with firsthand knowledge, regarding benefit to the award scope and compliance with award specific terms and conditions.
| Revision Date | Author | Description |
|---|---|---|
| 3-08-2024 | Office of Grants & Contracts Accounting | Editorial updates. |
| 02-24-2022 | Office of Grants & Contracts Accounting | Updated timeline requirements for completing Cost Transfers and removed procedures. |
| 10-01-2015 | Office of Grants & Contracts Accounting | Updated Non-Personal Service Cost Transfers Requiring Special Approval Authorization for externally-funded Sponsored Projects from 120 days beyond the original expense posting date to 90 days aligning with close-out requirements of OMB 2 CFR 200. |
| 11-05-2014 | Office of Grants & Contracts Accounting | Align with requirements of 2 CFR 200 |
| 04-01-2014 | Office of Grants & Contracts Accounting | Administrative review |
Facilities & Administrative (F&A) Cost Rates
Facilities & Administrative (F&A) Cost RatesGeorgia Institute of Technology/Georgia Tech Research Corporation utilizes Facilities and Administrative (F&A) rates to obtain recovery of costs, other than direct costs, incurred to support sponsored projects.
This cost accounting policy is based on OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200), Section 200.414 which states: "For major IHEs (Institutions of Higher Education), indirect (F&A) cost must be classified within two broad categories: "Facilities" and "Administration".
This policy is applicable to expenditures incurred on sponsored projects.
Definitions:
| Facilities costs | Facilities costs include depreciation and use allowances, interest on debt associated with certain buildings, equipment and capital improvements used for sponsored projects, operation and maintenance of plant expenses incurred for space used for sponsored projects, and allocated library expenses. |
| Administrative costs | Administrative expenses include the allocated portion of general administrative and general expense, departmental administration, sponsored project administration, and the allocated portion of student services administration. |
| Modified Total Direct Cost (MTDC) | MTDC consists of all salaries and wages, fringe benefits, materials and supplies, services, travel, and sub-grants and sub-contracts up to the first $25,000 each; and excluding equipment, capital expenditures, charges for tuition remission, rental costs, scholarships and fellowships, participant support costs, as well as the portion of each sub-grant and sub-contract in excess of $25,000. |
Facilities and Administrative costs (previously referred to as indirect costs) are comprised of two main categories: Facilities costs and Administrative costs. (See definitions above.) The distribution base used to determine F&A Rates is the Modified Total Direct Cost (MTDC) as defined by OMB Uniform Administrative Requirements (2 CFR 200) . An F&A rate is expressed as a percentage multiplied times the appropriate cost base on the grant or contract to determine the amount of F&A cost to be charged. The F&A cost is billed to the sponsor along with direct costs.
Facilities and Administrative (F&A) rates are determined on an annual basis according to the provisions of OMB Uniform Administrative Requirements (2 CFR 200), Section 200.414, and audits by the Defense Contract Audit Agency (DCAA), with negotiation and approval of rates by the Department of Navy, Office of Naval Research (ONR). The Institute and ONR negotiate F&A rates to be used over a period of years, based on the audited rate proposal report.
The negotiated F&A rates are to be used on externally-funded grants and contracts. Other sponsors, including the State and private foundations, tend to limit, by their own policy, the F&A rate they are willing to pay. Federal training and fellowship grants, clinical trials and drug studies also limit the F&A rate.
Types of F&A Rates
Three F&A rate types and five standard F&A rates are in place and applicable to sponsored work performed by the academic units of Georgia Tech (excluding GTRI). The applicable rate types and standard rates are described as follows:
- Organized Research
Research and development activities financed by external sponsors that are separately budgeted and accounted for by the Institute.- Federal Capped Rate – Incorporates all administrative limitations imposed by the Federal government. Rate is applicable to all Federal awards, all Department of Defense (DOD) Grants, and to DOD contracts awarded before November 30, 1993.
- Federal Uncapped Rate – Incorporates only the departmental administration limitation imposed by the Federal government. Rate is applicable to DOD Contracts awarded on or after November 30, 1993 in accordance with DFARS 231.303(1).
- Industrial Rate – Fully-burdened without administrative limitations. Rate is applicable to industrial awards.
- Instruction
Conventional academic instruction and related activities financed by external sponsors that are separately budgeted and accounted for by the Institute. There is only one standard rate associated with this rate type. - Other Sponsored Activities
Program and projects financed by external sponsors which involve the performance of work other than instruction and organized research. Among these activities are included programs designated as Community or Public Services. Examples include conferences, institutes, general advisory services, reference bureaus, consulting, and similar non-instructional services to particular sectors of the community. There is only one standard rate associated with this rate type.
Determination and Application of Federal F&A Cost Rates
F&A rates approved by ONR on a “Predetermined” or “Fixed” basis are treated as fixed rates throughout the competitive segment of the Federal sponsored agreement. A competitive segment is a period of years approved by the Federal funding agency at the time of the award. If negotiated rate agreements do not extend through the life of the sponsored agreement at the time of the initial award, the negotiated rate for the last year of the sponsored agreement is extended through the end of the life of the sponsored agreement.
Contact the Grants and Contracts Accounting Department at gc.ask@business.gatech.edufor additional guidance related to F&A rates at Georgia Tech.
To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at:
https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508
| Revision Date | Author | Description |
|---|---|---|
| 08-23-21 | Office of Grants & Contracts Accounting | Updated hyperlinks |
| 12-30-14 | Office of Grants & Contracts Accounting | Align with requirements of 2 CFR 200 |
| 07-01-12 | Office of Grants & Contracts Accounting | Administrative review |
| April 2015 | Office of Grants & Contracts Accounting | Updated based on OMB Uniform Requirements |
Fringe Benefits Cost Rates
Fringe Benefits Cost RatesGeorgia Institute of Technology/Georgia Tech Research Corporation utilizes Institute and Sponsor-Funded Fringe Benefits rates to charge benefiting activities for the cost of all employees’ fringe benefits. This policy reduces the amount of accounting required to accurately distribute fringe benefits expenses to benefiting activities.
This cost accounting policy is based on OMB Uniform Administrative Requirements, Section 200.431 (2 CFR 200) which states: “except as provided elsewhere, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, employee agreement, or an established policy of the institution”.
This policy is applicable to all employees eligible for Institute fringe benefits.
Institute and Sponsor-Funded Fringe Benefits rates are determined on an annual basis according to the provisions of 2 CFR 200, and audits by the Defense Contract Audit Agency (DCAA), with negotiation and approval of rates by the Department of Navy, Office of Naval Research (ONR). Upon approval by ONR, rates are used to charge fringe benefits expenses to institute-funded and sponsor-funded activities and projects during the fiscal year. Following the end of the fiscal year, the actual fringe benefits rates are determined. If Fringe Benefits rates have been approved on a “Fixed with Carry-forward Basis”, any amount of over or under-recovery of expense is incorporated into the next fringe benefits rate proposal. This procedure provides for the collection or repayment of any over or under-recovery of fringe benefit expenses.
The following benefits are included in the Institute and Sponsor-Funded Fringe Benefits rates for the academic units of Georgia Tech (excluding GTRI):
- Social Security
- Life Insurance
- Health Insurance
- Retirement
- Termination Vacation Leave
- Other Non-Payroll Benefit Expenses – Includes Worker’s Compensation, Unemployment Compensation, Retiree Group Insurance
Types of Fringe Benefits Rates
Five Personal Services Cost Groups have been identified for purposes of determining and applying the fringe benefits rates. The classes of employees and types of payments included in each of the five groups are as follows:
1. Partial Benefits - Social Security Benefits only; Covered employees include
- a. Temporary classified persons
- b. Temporary academic or research professionals not eligible for retirement, health insurance, and life insurance programs or not electing coverage under the plans
- c. Part-time employees employed for less than 50% of a full work schedule
- d. Additional compensation payments not covered by retirement programs
- e. Other payments to employees to cover moving expenses, awards, termination pay and other miscellaneous payments not covered by retirement programs
2. Full Fringe Benefits - All Benefits noted above; Covered employees include:
- a. Regular full-time faculty
- b. Principal Investigators
- c. Professional and administrative staff
- d. Joint staff
- e. Temporary academic or research professionals covered by applicable retirement, health insurance, and life insurance programs
- f. Bi-weekly permanent employees
- g. Part-time employees employed for at least 75% of a full work schedule
3. Limited Benefits – Social Security, Retirement, Termination Vacation Leave, and Other Non-Payroll Benefits; Covered employees are those employed for at least 50%, but less than 75% of a full work schedule, including:
- a. Regular faculty
- b. Principal Investigators
- c. Professional and administrative staff
- d. Joint staff
- e. Temporary academic or research professionals covered by applicable retirement programs
- f. Bi-weekly permanent employees
4. Graduate Student Health Insurance - Covered employees include:
- a. Graduate Research/Teaching Assistants who qualify for the graduate tuition remission award. See G&C Policy 3.17 “Graduate Student Tuition Remission Program” for additional information on qualifications.
5. No Benefits – Applicable to all other student employees enrolled full-time and working less than 20 hours per week.
Contact the Grants and Contracts Accounting Department at gc.ask@business.gatech.edu for additional guidance related to Fringe Benefits rates at Georgia Tech.
To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508
| Revision Date | Author | Description |
|---|---|---|
| 12-08-2014 | Office of Grants & Contracts Accounting | Align with requirements of 2 CFR 200 |
| 04-01-2012 | Office of Grants & Contracts Accounting | Administrative review |
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Graduate Student Tuition Remission Program (GSTRP)
Graduate Student Tuition Remission Program (GSTRP)Georgia Tech developed and implemented a plan in 1996 named the Graduate Student Tuition Remission Plan (GSTRP). This plan was reviewed and approved by the Office of Naval Research (ONR). Since that time annual rate studies have been provided to ONR that are audited by the Defense Contract Audit Agency (DCAA) to produce approved rates for each fiscal year.
The key features of this program are:
- The Tuition Remission Award is managed through our graduate coordinators in each academic department. Upon approval of the appointment as a Graduate Research Assistant or Graduate Teaching Assistant (GRA/GTA) the home department of the student will enter a waiver code into the student system and then a credit is processed to the student's account for the fee reduction for the academic term (set on an annual basis). All GRA/GTA appointments are processed in this manner. The fee reduction is charged against one of two ledger accounts based on whether the reduction is for in-state or out-of-state tuition.
- Part of the requirement for the appointment as a GRA/GTA includes the appointment to provide services to GIT at 33% to 50% time, registered for at least 12 credit hours of which 9 are letter grade/pass/fail. GRA/GTA's must be hired in the appropriate job code for a GRA/GTA in Human Resources. These appointments are made by the academic departments and the charges will be made against appropriate benefiting activity.
- On a monthly basis, the Salary Planning and Distribution (SPD) System identifies the GRA/GTA payroll charges to sponsored projects and charges the sponsored project the approved monthly rate. If the student provides services to multiple projects, the charge is prorated. The charge to the sponsored project is offset by a credit to a Revenue Account- Sponsored Funded Fees.
- Waivers of GSTRP charges to sponsored projects are considered by the Office of the Provost when required. Any such request should identify the unique features of the sponsored project that might warrant this special accounting treatment.
Participant Support Stipends Or Subsistence Allowances
Participant Support Stipends Or Subsistence Allowances jbarber32Memorandum Of Understanding
Memorandum Of Understanding jbarber32MEMORANDUM OF UNDERSTANDING
PARTICIPANT SUPPORT STIPENDS OR SUBSISTENCE ALLOWANCES
Note: This Memorandum of Understanding is to be prepared and submitted with each request to disburse participant support stipends or subsistence allowances to individuals who participate in sponsored conferences or research or instructional training programs.
Name of Program Project/Fund Number
Department/Unit Month/Day/Year
Participant is to place an (X) in the box below and complete the signature section indicating that you understand your obligation(s) regarding the reporting of stipend or subsistence allowances as taxable income on your tax return.
I am a United States Citizen or a Resident Alien, and I am participating in a research or instructional training program. To the best of my knowledge I am performing activities designed to train individuals in the performance of instructional or research projects, and this is not work the Institute would employ individuals to perform. I understand that I am not a Georgia Institute of Technology employee for payroll tax withholding purposes, and I am not covered by Worker’s Compensation under Georgia Law. Georgia Institute of Technology will issue an IRS Form 1099 for these payments. Furthermore, I understand that it is my responsibility to determine my tax liability and file my United States tax return with the IRS.
Definition of Participant Support Stipends or Subsistence Allowances
Participant Support stipends or subsistence allowances are paid to help defray the costs of personal maintenance while participating in a conference or training activity. Participants may be paid a stipend, per diem or subsistence allowance, based on the type and duration of the activity, as outlined in the pertinent sponsored program announcement and in the grant instrument. Such allowances must be documented and represent reasonable costs, in conformance with the Georgia Institute travel policies and procedures.
Definition of Participant Support Reimbursement of Expenses
Travel costs of participants in research of instructional training programs may be allowable as outlined in the pertinent program announcement and in the grant instrument.
Printed Name of Participant Social Security Number
Signature of Participant Date
Signature of Departmental Representative Date
Distribution: Accounts Payable; Participant; Department
Processing Participant Support Stipends Or Subsistence Allowances
Processing Participant Support Stipends Or Subsistence AllowancesParticipant Support Stipends or Subsistence Allowances
Participant Support stipends or subsistence allowances are paid to help defray the costs of personal maintenance while participating in a conference or training activity. Participants may be paid a stipend, per diem or subsistence allowance, based on the type and duration of the activity, as outlined in the pertinent sponsored program announcement and in the grant instrument. Such allowances must be reasonable and conform to Institute policies. A Memorandum of Understanding (MOU) between the department/unit and each participant is recommended. Please refer to G&C Policy No. 3.12.4.a – Memorandum of Understanding to obtain an MOU template.
Human Subject/ Research Participant payments are defined differently from Participant Support and are not included under the purview of this policy. Please see Georgia Institute of Technology Institutional Review Board Policies & Procedures – XIV “Compensation and Incentives for Research Participation.” Questions regarding these payments may be directed to ap.ask@business.gatech.edu.
Participant Support Reimbursement of Expenses
Travel costs of participants in research of instructional training programs may be allowable as outlined in the pertinent program announcement, the grant instrument, and Georgia Tech policy. For participant expense reimbursements, the participant should retain original receipts and submit only copies with the reimbursement request.
Participant Support Payments to GT students
Participant Support payments can be made using one of the following methods:
- Payment through the Accounts Payable Office using an AP Payment Request Form (formally known as the Check Request form) and the recommended MEMORANDUM OF UNDERSTANDING - PARTICIPANT SUPPORT STIPENDS OR SUBSISTENCE ALLOWANCES for direct payment to the participants.
- Payment through Financial Aid (ie: SURE, FACES) using an appropriate project specific to Undergraduate or Graduate students (i.e., projects with a 997 or 998 prefix).
- Payment through payroll if the participant is being paid a stipend and is already paid as a student employee through payroll. The stipend amount for students already paid through payroll must be set up in the SPD/Payroll system by the department. A subproject should be set up in the accounting system within the same fund for the participant support costs with a zero percent F&A rate.
Payments to non-student participants
Submit an AP Payment Request Form (Formally Check Request Form), Vendor Profile Form, and a recommended MEMORANDUM OF UNDERSTANDING - PARTICIPANT SUPPORT STIPENDS OR SUBSISTENCE ALLOWANCES to the Institute’s Accounts Payable department. The check box on the AP Payment Request Form form should be marked "Non-GT Student Training Stipends, Non-Employee Awards (Sponsored Funds Only)" if used for stipend payments and "Reimbursement" for other expense reimbursements. For travel reimbursement see Policy No. 6.16 – Non-Employee Travel.
For additional information regarding the AP Payment Request Form, please contact ap.ask@business.gatech.edu or go to www.procurement.gatech.edu.
IRS Regulatory Requirements
The Institution will report participant support payments to the individual on IRS Form 1099-Misc at the end of each year or W-2 if the student/participant is paid through payroll.
Contact the Grants and Contracts Accounting Department at gc.ask@business.gatech.edu for specific guidance related to managing sponsored projects at Georgia Tech.
Personal Services Reporting Using the Plan Confirmation System
Personal Services Reporting Using the Plan Confirmation SystemThis policy outlines requirements and procedures to facilitate the Georgia Institute of Technology (GT) compliance with the Federal Government's Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR 200), hereafter referred to as Uniform Requirements. The Uniform Requirements establish principles for determining costs applicable to grants, contracts, and other agreements between Federal agencies and non-Federal entities (i.e., educational institutions). All Federal agencies that sponsor research and development, training, and other work at educational institutions must apply the provisions of the Uniform Requirements in determining the costs incurred for such work.
GT must have financial systems and internal control procedures in place to assure compliance with the terms and conditions of these agreements and State and Federal regulations concerning sponsored programs. The documentation and support of the distribution of salary and fringe benefits charged to sponsored programs is a critical element of compliance. The requirements for this documentation are defined in section 200.430(i) of the Uniform Requirements and require salary and fringe benefits to accurately reflect the work performed.
GT prepares invoices to sponsors based on the information in the Institute's accounting records. The salary and fringe benefit charges that appear on these invoices are calculated by the GT Commitment Accounting System and confirmed in the GT Plan Confirmation System (PCS). Salaries charged to sponsored awards are approved by the PI (and/or their financial staff) in accordance with the terms of the award and:
- Are allocable for the project scope,
- Are allowable by the project budget,
- Are reasonable and have been incurred within the Period of Performance, and
- Have been incurred according to all GT accounting policies and procedures.
The distribution of salary and fringe benefits to sponsored projects is a sensitive issue in GT’s operation of its sponsored programs; it therefore receives scrutiny by GT officers, sponsor representatives, and federal government contracting officers and auditors. Learn more about Commitment Accounting requirements here.
Compensation for Personal Services
Compensation for personal services covers amounts earned to date for salary and fringe benefits services of employees rendered during the period of performance under sponsored agreements or other institutional activity. The payroll distribution, which is incorporated into the official records of GT, must reasonably reflect the activity for which employees are compensated by GT, and it encompasses sponsored and all other activities.
Plan-Confirmation System – Employee Salary Charged to External Sponsored Awards and Cost Share
Under the Plan Confirmation System the distribution of salaries and fringe benefits reflects budgeted, planned, or assigned work activity based on the initial annual budget. This distribution is updated throughout the year to reflect any significant changes in work.
Workload Assignment Forms (WAFs)
The WAF, which includes both actual compensation to date and planned compensation (encumbrances) should be reviewed by employees on a monthly basis. These forms should be retained during the fiscal year until the Annual Statement of Reasonableness of Salary Charges (ASR) is confirmed. Unit financial managers may also produce copies for review by individual employees upon request. Employees must report workload changes to their supervisor in a timely manner. See “Employee Responsibilities” in Section 7 of this policy.
Significant Changes in Workload Distribution
Commitment Accounting provides for the modification of an individual's salary distribution, commensurate with any significant change in the employee's workload or the ratio of activities comprising the workload. Specific events, which may cause a significant change in workload distribution include, but are not limited to:
- The beginning or ending of work on a sponsored award,
- A material change in the scope of work on a sponsored award,
- An increase or decrease in the number or level of courses taught,
- A new committee or major administrative assignment or relief from a committee or major administrative assignment,
- The beginning or ending of a sabbatical leave, leave without pay, or prolonged sick leave,
- Status changes from part-time to full-time or vice versa.
The system does not require an adjustment in the employee's workload assignment for day-to-day, or short-term, changes in work schedule. However, the Commitment Accounting department does require an adjustment for all significant changes to an employee's workload. As a general rule, a change applicable to a given project or activity of 5% or more of an employee's total effort over the course of the academic term would warrant an adjustment.
Changes in an employee's workload distribution for future periods are generally acceptable but are subject to the standard documentation requirements noted below. Future period workload distributions should be confirmed monthly via the WAF.
Retroactive Changes in Workload Distribution
Retroactive changes to payroll distributions must be subjected to the closest scrutiny. These types of changes indicate a contradiction of previous monitoring reviews and, for that reason, should be limited to the correction of errors. If a retroactive change must be made, it must be approved and documented in accordance with the requirements found in the Commitment Accounting policy.
Standard Documentation Requirements
GT authorizes the principal investigator (PI) and the properly authorized unit designee (financial manager and staff) to have primary responsibility for the management of sponsored awards. The manual/electronic signatures and/or a system password of those individuals is generally considered sufficient documentation to support standard workload allocation changes.
Primary supporting documentation for PCS salary charges during a fiscal year are defined in the Commitment Accounting Policy.
Retroactive changes that cross fiscal years may be made in extraordinary circumstances by journal entry when supported by appropriate documentation, including a revised Annual Statement of Reasonableness of Salary Charges (ASR) signed by the employee or someone with firsthand knowledge and the departmental approver.
Annual Statement of Reasonableness (ASR) of Salary Charges
The Plan-Confirmation System requires an attestation to be completed annually by the employee, principal investigator, or responsible official that:
- compensation is reasonably allocated to all work performed, and
- compensation was charged to sponsored agreements as direct charges, or
- compensation was charged to both sponsored and non-sponsored funding sources, or
- compensation was charged to multiple non-sponsored funding sources.
The Office of Grants and Contracts Accounting will notify employees to complete the ASR certification, following the completion of the fiscal year.
ASR Signatory Requirements – Certification of Effort
The Annual Statement on the Reasonableness of Salary Charges (ASR) is designed for the employee to confirm that the distribution of salary charges represents a reasonable estimate of the work performed during the stated period. ASRs must be completed annually for any individuals with salary charges on sponsored funding sources. In most instances, only the employee has the information required to complete this certification and therefore ASRs should be completed and signed by the covered employee.
The manual ASR does provide a second certification section to be used in limited instances when the covered employee is not available to complete the certification. When the employees is unable to complete the ASR, the certification may be signed by the employee’s supervisor, PI, or other organizational unit head, with firsthand knowledge of all the employee's activities using suitable means of verification that the work was performed. If the responsible official cannot certify that they have personal familiarity with all of the employee's activities, then the employee is required to sign the statement. In some cases, an employee may be involved in a number of activities under different supervisors, and no single person other than the employee has firsthand knowledge of all their activities. In these cases, the employee must sign the documents.
Unit Financial Manager's Certification
The PCS also requires that the appropriate financial manager in each unit review the ASR statements before returning to them Grants and Contracts Accounting. The financial manager should sign and date each ASR to indicate that the review has been done.
This policy applies to individuals who charge time to sponsored funding sources across all units of the Georgia Institute of Technology, with the exception of the Georgia Tech Research Institute (GTRI). GTRI employees should reference GTRI Policy 6190 - Reporting Time and Paid Leave.
|
Annual Statement of Reasonableness (ASR) |
The Annual Statement of Reasonableness report, which is produced annually for employees using the PCS, is used for documenting the confirmation and certification by employees that their effort allocation was reasonable and correctly posted in the past fiscal year. This statement shows the amount of salary charged to each of the employee's sponsored awards along with all other activities compensated by GT and the percentage of each amount to the total effort. The manual ASR provides a means of making adjustments in payroll distributions if corrections are required. |
| Cost Share | A portion of an externally funded award where GT resources are committed and tracked in the Grants Management System. |
| Distribution |
(Payroll) distribution relates to how an individual's compensation is allocated across various funding sources in relation to work performed. |
|
Externally Funded Awards |
An award or agreement by an external Federal or Non-Federal entity that is separately budgeted for in the Grants Management system. Georgia Tech Foundation and Georgia Tech Research Corporation funds are considered to be internally funded. |
|
Period of Performance |
The time during which new obligations can be incurred to carry out work on a sponsored award. A Federal awarding agency must include a start and end date of the Period of Performance in the award. |
|
Workload Assignment Form (WAF) |
The Workload Assignment Form (WAF) report is produced monthly for employees covered by the PCS to review their effort allocation for accuracy and make timely corrections. Each monthly WAF covers an entire fiscal year, July 1 to June 30, including both actual payments and planned salary distribution for future periods. These forms should be retained by employees covered by PCS during the fiscal year until the ASR is confirmed. |
Forms
To obtain hard copy forms, please contact the Office of Grants & Contracts Accounting via Service Now.
7.1 Departmental Responsibilities
Unit financial managers should provide instructions and support to employees covered by the PCS to help employees understand their responsibilities with the system. Training is supported by the Grants and Contracts Accounting Office via an on-line web tutorial. More information can be found here regarding training. Once completed, an electronic acknowledgement is recorded for all employees whose salaries are charged directly to externally sponsored awards.
7.2 Principal Investigator Responsibilities
Each GT PI is responsible for effectively overseeing and managing their sponsored awards based upon his/her knowledge of the field of study and capabilities to conduct the research in an efficient and productive manner.
7.3 Employee Responsibilities
Employees are responsible for:
- Completing required PSC training and attestations,
- Reviewing their respective WAF during the fiscal year until the ASR is confirmed,
- Communicating WAF inaccuracies or discrepancies, to their supervisor immediately,
- Reviewing and confirming the ASR by the published deadlines,
- Providing supporting documentation as needed for WAF and ASR confirmations,
- Reporting significant changes to the actual effort given to an award or planned to be given to an award,
- Notifying Commitment Accounting via Service Now in the event of supervisor inaction on WAF and ASR reconciliations.
To report suspected instances of ethical violations, please visit Georgia Tech’s Ethics Helpline, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508
| Revision Date | Author | Description |
|---|---|---|
| 07/7/2021 | Office of Grants & Contracts Accounting | Editorial updates. |
| 10-20-2020 | Office of Grants & Contracts Accounting | Updated in compliance with OneUSG Connect transition. |
| 10-17-2015 | Office of Grants & Contracts Accounting | Align with terminology of Fair Labor Standards Act (FLSA) |
| 10-01-2015 | Office of Grants & Contracts Accounting | Revise Special Documentation Requirements and Limitations – Externally-funded Sponsored Projects from 120 days beyond the original expense posting date to 90 days aligning with close-out requirements of OMB 2 CFR 200. |
| 11-05-2014 | Office of Grants & Contracts Accounting | Align with requirements of 2 CFR 200 |
| 04-01-2012 | Office of Grants & Contracts Accounting | Administrative review |
Project Close-out in Grants Management System
Project Close-out in Grants Management SystemThis policy summarizes the review process to financially close sponsored awards in the accounting records of the Georgia Institute of Technology in accordance with close-out requirements mandated by Federal regulations, including the Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR 200), sponsor requirements, and award terms and conditions.
The Office of Grants and Contracts Accounting is charged with the financial close-out of sponsored awards in the accounting records of the Georgia Institute of Technology for sponsored activity in Resident Instruction (RI), Georgia Tech Professional Education (GTPE), and the Enterprise Innovation Institute (EII).
All employees engaging in sponsored research activity.
Matching/Cost Sharing Funds
The Institute's contribution to an externally funded sponsored award when contractually obligated for awards accepted by the Office of Sponsored Programs (OSP) in the name of Georgia Institute of Technology or the Georgia Tech Research Corporation.
The Office of Grants and Contracts Accounting, in collaboration with financial representative in the campus units, is responsible for the financial close-out of sponsored awards in the Institute's accounting records for both external sponsored awards and restricted gift allocations funded by the Georgia Tech Research Corporation. Steps taken to complete the financial close-out process are as follows:
- Personnel in the Office of Grants and Contracts Accounting may review expenditures and obligations allocated to sponsored awards period of performance. The review may include, but is not limited to, review of transactions to ensure expenditures are within sponsor guidelines established in the award document and in compliance with applicable laws and institutional policies, including the Federal Government’s Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR 200).
- G&C personnel responsible for award close-out will work collaboratively with the campus unit financially responsible for the prime award. Any unrecorded activity must be verified by the G&C personnel as allowable in order to include those costs and/or unliquidated obligations in a financial report or final billing to the sponsor.
- In accordance with 2 CFR 200.344, the non-Federal entity must submit, no later than 120 calendar days after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award. This deadline may be extended based on requirements for specific sponsors or contract terms and conditions that indicate a due date other than 120 days after the performance end date.
- Grants and Contracts Accounting personnel are responsible for monitoring awards which have been financially closed with the sponsor but have outstanding action required by campus units. Until all internal adjustments are complete, the sponsored award will not be inactivated in the accounting records.
- At the time final payment from the sponsor is received and all internal actions have been processed (i.e., transfer of overrun costs to a discretionary funding source) in the accounting records, the Office of Grants and Contracts Accounting inactivates the award in the Institute's accounting records.
Fixed-price Sponsored Projects
Fixed-price sponsored awards will be closed in same manner as standard cost-reimbursable awards. In accordance with 200.201 (b)(3) of the OMB Uniform Requirements (2 CFR 200), written certification that the project or activity was completed or the level of effort expended must be obtained. If the required level of effort or activity was not carried out, the amount of the award must be adjusted.
The PI Fixed Price Close-out Certification must be completed and submitted to Grants & Contracts Accounting for review. After certification, immaterial residual balances (if any) remaining on fixed price awards will be transferred to a departmental GTRC allocation, net of applicable F&A expenses, to be managed by the Chair/Director of the department.
Frequently Asked Questions
Please refer to the Grants and Contracts Accounting web site at www.grants.gatech.edu for additional information
Principal Investigators, assigned delegates, and unit financial officers are responsible for providing proper oversight and management of sponsored awards during the performance and close-out periods.
Valuation and disposition of equipment and supplies, including computing devices, must be managed in accordance with 200.313 “Equipment” and 200.314 “Supplies” of the OMB Uniform Requirements (2 CFR 200).
To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508
| Revision Date | Author | Description |
|---|---|---|
| 09-09-2021 | Office of Grants & Contracts Accounting | Updated to align with 2 CFR 200, editorial updates to align with new financial system |
| 10-01-2015 | Office of Grants & Contracts Accounting | Revise close-out process for Firm Fixed Price awards |
| 11-05-2014 | Office of Grants & Contracts Accounting | Align with requirements of 2 CFR 200 |
| 04-01-2014 | Office of Grants & Contracts Accounting | Administrative review |
Record Retention - Federal Sponsored Projects
Record Retention - Federal Sponsored ProjectsThe policy is to explain the special record retention requirements governing Federal sponsored projects.
Georgia Tech is a unit of the Board of Regents of the University System of Georgia (USG). The Institute follows the official USG Records Retention guidelines. These guidelines (including retention periods) can be found at the following web link:
http://www.usg.edu/records_management/schedules/A
This policy is applicable to accounting records relating to Federal sponsored projects.
Standard payroll, procurement, accounts payable, travel, and general accounting supporting documentation is maintained centrally in accordance with USG retention guidelines.
P-Card, Electronic Cost Transfer (ECT) and other subsidiary expenditure documentation is maintained at the local unit level.
Additional Retention Requirements – Federal Sponsored Projects
Central sponsored program files, including award documentation, financial reports and summarized accounting system information are retained in accordance with the Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR 200), Section 200.333 – 200.337 – “Record Retention and Access”. Section 200.333, Retention requirements for records, states financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to an award must be retained for a period of three years from the date of submission of the finial expenditure report** or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.
Detailed Federal sponsored project expense records that exceed the USG/Institute retention period should be maintained by the home department of the Project/Sub-Project Principle Investigator in accordance with 2 CFR 200 requirements.
**Final Expenditure Reports are typically due 60-120 days after the final expiration date of the sponsored award.
Contact the Grants and Contracts Accounting Department at gc.ask@business.gatech.edu for additional guidance related to record retention for Federal sponsored projects at Georgia Tech.
To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at:
https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508
| Revision Date | Author | Description |
|---|---|---|
| August 2021 | Office of Grants & Contracts Accounting | Editorial update |
| April 2015 | Office of Grants & Contracts Accounting | Update per OMB Requirements |
| 12-30-14 | Office of Grants & Contracts Accounting | Align with requirements of 2 CFR 200 |
Unbillable Sponsored Costs - Cost Overruns / Sponsored Project Exceptions
Unbillable Sponsored Costs - Cost Overruns / Sponsored Project ExceptionsAlthough all expenditures and encumbrances are obligations of the Institute, only those costs to sponsored projects within the project performance period, approved award value, and terms and conditions of the award, are billable costs. Any other costs are unbillable and must be paid from alternative sources of funding. It is the fiscal responsibility of the incurring unit to cover costs obligated.
Untimely resolution of unbillable amounts may cause serious cash flow problems, may result in misstated financial statements, and may also result in unfavorable audit scrutiny.
After notification by the Office of Grants and Contracts (G&C) Accounting that unbillable costs have been incurred on an externally funded sponsored project, the unit will be given an opportunity to resolve the problem before the expenditure is moved to the unit's cost overrun project.
All employees engaging in sponsored research activity.
Advanced Project Number
A project to which expenses may be charged on behalf of an anticipated program prior to receipt of a grant or execution of an agreement, with approval from the Office of Sponsored Programs.
To assist with the identification of sponsored projects that need special attention and corrective action, G&C Accounting prepares a monthly exception report to identify all awards with expenditures in excess of available funds and/or active awards with expired term dates. The monthly exception report is distributed to G&C personnel, unit financial officers and appropriate Deans/Directors; representing formal notification to the incurring unit. Corrective action must be taken to clear unbillable amounts as identified each month in the Sponsored Project Exception Report.
In addition to the monthly reporting procedures, G&C Accountants will initiate additional action to clear unbillable costs on sponsored projects. When the assigned G&C Accountant determines that costs incurred are unbillable to the sponsor, the following steps are taken:
These corrective action procedures do not apply to sponsored projects established with OSP-approved Advance Project Numbers or to current projects pending receipt of official modifications. However, written proof/justification from the sponsor is required under these circumstances.
- G&C contacts the incurring department to determine if immediate action can be taken to resolve the unbillable costs. If the administrator indicates that action will be taken to clear all unbillable amounts within a reasonable time frame (typically 30-60 days), no additional action is required at that time. The assigned G&C Accountant may also contact the Office of Sponsored Programs (OSP) at this stage to determine if official modifications are pending.
- If action is not indicated by the department or there is no pending action indicated to resolve the outstanding unbillable costs, the project will be reported to a G&C Accounting Manager. Review and follow-up by G&C Accounting is on a continuing basis until the unbillable costs are resolved in some manner.
- If appropriate action is not taken by the incurring unit and no additional information is provided to substantiate the unbillable amounts within approximately 60-90 days, all questioned costs will be transferred to the unit’s cost overrun project. This cost transfer will typically be processed within 90 days of the reported exception but may occur sooner as required by applicable financial reporting and/or invoicing requirements. It should be noted that costs transferred to a unit’s cost overrun project may be redirected to other projects as appropriate and as approved.
Forms
Reports are available in the Web Grants Management (GM) system to assist Principal Investigators, assigned delegates, and unit financial officers in providing proper oversight and management of sponsored projects. Proper project management includes posting all appropriate expenses on a timely basis, ensuring that costs are allowable and allocable to the project, and ensuring that expenses do not exceed the authorized budget. The “90 Days to Expiration Report” and the “Project Status Report” are useful for identifying projects that are at or approaching the unbillable stage. These reports are accessible from the main menu of Web GM.
Additional information related to Web GM, including access requirements and training materials, may be accessed from the Grants and Contracts Accounting web site at www.grants.gatech.edu
Contact the Office of Grants and Contracts Accounting at gc.ask@business.gatech.edu for specific guidance related to managing sponsored projects at Georgia Tech.
Principal Investigators, assigned delegates, and unit financial officers are responsible for providing proper oversight and management of sponsored projects during the performance and close-out periods.
To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508
| Revision Date | Author | Description |
|---|---|---|
| 11-05-2014 | Office of Grants & Contracts Accounting | Align with 2 CFR 200 |
| 04-01-2014 | Office of Grants & Contracts Accounting | Administrative review |
Undesignated Sponsored Salaries
Undesignated Sponsored SalariesUndesignated Sponsored Instruction, Sponsored Research and Sponsored Other fund 20400 driver worktags are used as a means of facilitating the budgeting of personal services only when specific Award/Grant numbers are not yet known. Undesignated expenditures must be completely removed from the accounting records before the end of each fiscal year.
Undesignated driver worktags should only be used where there exists a high degree of assurance that the award(s) will be approved or where administrative delays have been encountered in the issuance of award documents and the assignment of Award/Grant driver worktags. Undesignated driver worktags are not a budgetary device to cover salaries for which adequate funding has not been identified and only hopes exist to cover them in the future. Undesignated worktags are not to be used as a means of balancing a budget and they should never be used when valid sponsored information is available. Undesignated worktags are to be used for salaries only. Non-salary expenses such as travel or materials and supplies should never be charged to undesignated worktags. Advance Award/Grant numbers can be assigned under specific circumstances as described in Institute Research Policy 2.7.
This policy applies to individuals who devote time to sponsored activities across all units of the Georgia Institute of Technology, with the exception of the Georgia Tech Research Institute (GTRI). GTRI employees should reference GTRI Policy 6190 - Reporting Time and Paid Leave.
An undesignated sponsored report is produced each month by the Commitment Accounting team for each unit and for the Office of the Executive Vice President for Research (EVPR).
For the first eleven months (July - May) of the fiscal year, any undesignated expenditures over 60 days will require justification in accordance with procedures managed by the Office of the EVPR.
Prior to the end of the fiscal year, any balances in the Undesignated Sponsored Projects must be removed and posted to an appropriate unit worktag or other allowable funding source.
Contact Commitment Accounting through ServiceNow for specific guidance related to managing salary allocations as Express Direct Retro (EDR) transactions.
Contact the Grants and Contracts Accounting Department through ServiceNow for specific guidance related to managing sponsored awards at Georgia Tech.
Personal Services and Effort Reporting guidance is available on the Grants and Contracts Accounting website at www.grants.gatech.edu.
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Commitment Accounting
Commitment Accounting will publish an aged undesignated summary report and deliver it to each department via email.
Grants and Contracts Accounting
Grants and Contracts Accounting will review and approve or deny salary cost transfers from undesignated to sponsored awards in accordance with Institute policy.
Salaries not moved from the undesignated driver worktag to the appropriate sponsored award in a timely fashion may be unbillable to external sponsors and therefore must be covered by the department’s state or discretionary funding.
To report suspected instances of ethical violations, please visit Georgia Tech’s Ethics Hotline a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508
Write-Off Requests
Write-Off RequestsThis procedure explains how to write-off cost overruns on sponsored awards.
Any budgetary unit incurring a cost overrun on a sponsored awards will be solely responsible for its removal.
The budgetary unit must submit a Request for Cost Transfer - Sponsored Award form in accordance with the procedures established and detailed elsewhere in the Policy Library.
- It is permissible to transfer an expense to the budgetary unit's current year's State funds or to discretionary sponsored funds if the expense causing the overrun is incurred in the current fiscal year. (Instruction or General Research funds - NEVER to Indirect Research)
- The expense must be written-off against current year funds for active awards. The budgetary unit must identify the current year's State account which is being used to cover the deficit.
Forms
The Request for Cost Transfer/Encumbrance - Sponsored Projects form may be obtained from the Office of Grants and Contracts Accounting.