Although sponsored programs are awarded based on the special competence of the proposing faculty and assembled research team, all solicitations (e.g., proposals or offers) for sponsored programs must be made by and, if selected for funding, issued to the University under its legal name: The Rector and Visitors of the University of Virginia. (For information about who is eligible to submit proposals and oversee the technical, fiscal, and administrative performance of sponsored programs, see University policy RES-011: Investigator Eligibility Requirements and Responsibilities Related to Sponsored Programs.)

1. Administrative Authority:
   The Office of Sponsored Programs (OSP) has primary administrative authority for the solicitation, clearance, negotiation, acceptance, and ongoing management of sponsored programs. Ongoing management includes, but is not limited to, financial management (e.g., application of appropriate facilities and administrative rates, sponsor invoicing/draws, financial reporting, and audit support) and contract management throughout the sponsored program lifecycle. OSP has the authority to establish institutional systems, processes/procedures, and controls to support these activities and to confirm compliance with applicable requirements (e.g., sponsor, institutional, state, and federal). In implementing its authorities, OSP shares information and works collaboratively with other units in the Office of the Vice President for Research; school officials and faculty; and the University research administration community as well as other units across the institution that engage in, enable, or support sponsored program activities. (For current information about sponsored program administrative systems, processes/procedures, and controls, see the OSP website.)

2. Sponsored Program Documents:
   Sponsored program documents [e.g., proposals including budgets, research awards (i.e., grants, contracts, and cooperative agreements), modification requests, representation and certification documents, and other sponsored program contracts] must be submitted for review and approval via the University’s electronic research administration system. The requirement for prior review and approval does not apply to interim or final technical/progress reports which are typically submitted to the sponsor by a member of the research team; however, these reports are expected to be uploaded to the University’s electronic research administration system following submission to the research sponsor. Financial management documents (e.g., invoices, financial reports, and supporting documents) submitted directly to the sponsor are not required to be routed via or stored in the University’s electronic research administration system.

3. Sponsored Program Contracts:
   Sponsored program contracts must be executed by an authorized signatory in OSP (see University policy FIN-036: Signatory Authority for Executing University Contracts). Sponsored program contracts include, but are not limited to, certain research awards (i.e., contracts and collaborative research and development agreements), collaboration agreements, memoranda of agreement or understanding, nondisclosure agreements, and agreements related to the transfer and use of materials and/or data when associated with the conduct of research.

4. Financial Transactions:
   All financial transactions must be processed through the University’s financial system(s) of record (see University policy FIN-048: Safeguarding and Stewardship of University Financial Records). Reconciliation of accounting records are performed by the units (see University policy FIN-023: Reconciling Unit Accounting Records). Costs must be treated consistently to conform to sponsor policies, contract or grant special provisions, institutional requirements (see University policy FIN-017: Consistent Treatment of Sponsored Program Costs), and in accordance with Federal cost principles:

   • Costs claimed must be necessary (i.e., essential for the performance of the Federal award).
   • Reasonable (i.e., not exceeding an amount that a prudent person would incur).
   • Allocable (the charges specifically benefited that particular Federal award or cost objective).
   • Allowable (i.e., per institutional, sponsor, Federal, and State cost principles).

   Unallowable or unallocable costs must be moved off the sponsored program to another fund source that can accept such charges (e.g., gift, endowment, or residual balance account) as soon as they are identified.

5. Compliance with Policy:
   Failure to comply with the requirements of this policy may result in disciplinary action up to and including termination or expulsion in accordance with relevant University policies.

   Questions about this policy should be directed to the Office of Sponsored Programs.