RES-009: Compliance with Sponsor Requirements

Date: 02/15/2019 Status: Final
Last Revised: 07/21/2021
Policy Type: University
Oversight Executive: Vice President for Research
Applies To:

Academic Division and the College at Wise.

Table of Contents:

Policy Statement

Reason for Policy:

In accepting a sponsored program, the University assumes the responsibility for fulfilling the institutional, sponsoring agency, Federal, and State requirements. These requirements may be specifically contained in the agreement or they may be incorporated by reference to guidelines issued by the sponsor in special publications or directives. The University has established policies and procedures to provide reasonable assurance that internal controls are in place to manage sponsored awards in compliance with Federal, State, and other non-federal sponsor requirements, statutes, and terms and conditions of the award.

Definition of Terms in Statement:
  • Cost Transfers:

    A journal entry to transfer an expense altering the original recorded transaction in the financial system. More specifically, a labor adjustment is a salary cost transfer, where adjustments are made in the Oracle Labor Distribution module to transfer payroll expenses.

  • Federal Award:

    A grant, contract, or cooperative agreement received directly from a Federal agency as well as federally funded sub-awards received by the University from other organizations.

  • Principal Investigators/Project Directors and Other Key Personnel:

    Individuals whose effort is absolutely essential to the success of the proposed activity, either because of their critical leadership positions within the proposal (and consequently their intellectual guidance) or because of the uniqueness of the expertise they are contributing relative to the proposed scope of activity. ‘Key personnel’ typically include research scientists, principal scientists, and senior scientists, depending on their intellectual contribution to the proposed scope of activity. Typically, replacement of any of these individuals requires approval from the sponsor. Importantly, the status of ‘Principal Investigator/Project Director’ and ‘key personnel’ does not necessarily imply salary support from the sponsor.

  • Sponsored Program:

    Any externally funded research, public service, or scholarly activity (including hosting or attending conferences) at the University that has a defined scope of work often including a set of specific programmatic objectives and/or deliverables, and line-item-based budget, providing the basis for sponsor expectations and awardee accountability (i.e., a reciprocal transfer of something of value). Sponsored programs are funded through agreements that usually include terms and conditions for the disposition of tangible properties and outcomes (e.g., equipment, records, specified technical reports, theses, or dissertations) or intangible properties and outcomes (e.g., rights in data, copyrights, and inventions). Note: The terms sponsored program, sponsored project, and/or sponsored activity are often used interchangeably.

Policy Statement:

As sponsored award recipients, it is critical for the University to be cognizant of and comply with policies, standards, and laws that govern the sponsored programs. These requirements may be specifically contained in the agreement or incorporated by reference to guidelines issued by the sponsor in special publications or directives. The University has established effective internal controls in tracing sources of funds to the level of expenditures to exhibit that the funds are expensed following sponsor and award specific terms and conditions, including Federal statutes and regulations.

Expenditures on Federal awards are governed by the Federal cost principles: costs claimed must be necessary (essential for the performance of the award), reasonable (not exceeding an amount that a prudent person would incur), allocable (the charges specifically benefited that particular award or cost objective) and allowable (per institutional, sponsor, Federal, and State cost principles). Costs must be treated consistently to conform to sponsor policies, contract or grant special provisions, and the University’s policies. Reconciliation of accounting records are performed by the units per University policy and unallowable or unallocable costs must be moved off via cost transfers or labor adjustments from the sponsored award to another fund source that can accept such charges (e.g., PI’s gift/endowment, etc.) as soon as they are identified.

The principal investigator is designated by the University to direct the project or program being supported by the sponsored award in accordance with the terms and conditions of the award, and is responsible for technical, fiscal, and administrative management of the sponsored activity in accordance with all applicable University, Federal, State, and sponsor requirements.

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.


OSP Procedures, specifically:

OSP-Budgeting Direct Costs on Sponsored Programs
OSP-Cost Transfers on Sponsored Awards

Monthly Grants Accounting (GA) Reconciliation Procedure

Related Information:

Policies and Guidance on Research Data Security:
IRM-003: Data Protection of University Information Note: This policy covers unpublished research data. Consistent with this policy and the University Data Protection Standards, when a discrepancy exists between a University data protection standard and an applicable external data protection standard the more stringent will apply. Research Data Security content on the Vice President for Research’s website provides information on sponsor requirements/expectations and links to UVA resources available to support research.

OSP Policies, specifically:

FIN-017: Consistent Treatment of Sponsored Program Costs
FIN-027: Time and Effort Certification
FIN-051: Proposing and Managing Cost Sharing on Sponsored Programs

FIN-023: Reconciling Unit Accounting Records
RES-005: Financial Conflicts of Interest for Research Investigators
2 CFR 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards

Major Category: Research Administration
Category Cross Reference: Finance and Business Operations
Next Scheduled Review: 03/19/2024
Approved by, Date: Policy Review Committee, 02/15/2019
Revision History: Added Compliance section 7/21/21; Confirmed 3/19/21; Updated Related Information 2/23/21.
Supersedes (previous policy):
VIII.C.1: Compliance with Sponsor Requirements.