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Fort Lewis College Official Seal

Policy identification number: SPON-002

File: Sponsored Research & Federal Relations

Sponsored Grants and Contracts, Budgeting, Accounting, and Reporting

Policy Summary

This policy establishes the required fiscal management and financial reporting, and procedures for sponsored programs and contracts.

Policy Owner

President

Approval Date

June 10, 2019

Effective Date

June 10, 2019

Search Terms

sponsored grants and contracts, budgeting, accounting, reporting, president, s 

Scheduled for Review

Spring 2024

I. Policy Statement

Sponsored programs are established through contracts and grants negotiated by the College with outside agencies.

  1. Under normal circumstances, expenditure commitments may not be made against a specific sponsored program before:
    1. A contract, grant document, or other authorizing document has been received by the College.
    2. The grant must be entered and approved in Cayuse.
    3. An approved Project Data Sheet has been filed with the Controller’s Office and an appropriate organization number has been assigned.
  2. The Principal Investigator (PI) shall have the primary responsibility of grant compliance for expenditures of program funds. The PI is responsible for keeping supporting documentation for all purchases made with grant funds and to provide that supporting documentation to the Sponsored Research Office, Controller’s Office, and granting agency when requested. The PI is required to follow all College procurement rules and follow all Uniform Guidance requirements on federal grants.
  3. If the PI requests to use award funds for purposes different from that approved in the original grant proposal and original budget approved by the granting agency, it is the PI’s responsibility to obtain permission in writing in advance from the granting agency.
  4. Granting agencies will provide documentation to awardees showing the authorized funding amount on a project. Grants must have authorized funding for the PI to begin or continue making expenditures on a grant. For multi-year grants, authorized funding is typically granted on an annual basis. PI’s must obtain approval from granting agencies to make expenditures on a grant in excess of authorized funding amounts or outside of the grant’s approved performance period. If the granting agency allows advance spending on a grant award and can provide the College documentation approving advance spending, the College will allow the PI to make expenditures on the grant in advance of the grant’s performance period.   
  5. Equipment purchased with grant funds will be transferred, sold, or disposed of in accordance with the granting agency’s rules. Equipment purchased with grant funds becomes property of the College. If a PI or other outside party wants to purchase equipment obtained with grant funds from the College, the request will only be considered if the equipment does not have any benefit or use for the College or students.
  6. The PI is not authorized  to waive indirect costs in the grant budget or to use indirect costs towards matching requirements. Indirect costs should be included in the grant budget using the sponsor’s rate, if specified, and if the sponsor does not specify a rate, the College’s federally negotiated indirect cost rate will be used. 

II. Reason for Policy 

All monies solicited from external funding sources by FLC faculty and staff are required to follow a set of procedures to ensure compliance with College fiscal rules as well as federal and state requirements for monitoring and tracking of external funds solicited on behalf of the College. 

III. Responsibilities 

For following the policy: Principal Investigator, Project Director

For enforcement of the policy: Director of Sponsored Research and Federal Relations

For oversight of the policy: President

For notification of policy: Policy Librarian

For procedures implementing the policy: Principal Investigator, Project Director, Office of Sponsored Research and Federal Relations, Controller’s Office 

IV. Definitions 

Sponsor/Granting Agency:  The source of the external funds to support a sponsored project (grant or contract).  The sponsor/granting agency can be a federal, state or local government entity, corporation, foundation or trust.

Principal Investigator (PI): The primary individual responsible for the preparation, conduct, and administration of a research grant, cooperative agreement, training or public service project, contract, or other Sponsored Project in compliance with applicable laws and regulations and institutional policy governing the conduct of sponsored research.

Project Data Sheet (PDS):  The form the PI must complete to receive a budget code to access the grant funds once they have been awarded. The PDS tells the Controller’s Office which budget categories and period of time to use in setting up the grant budget. The PDS form is on the Sponsored Research website: https://www.fortlewis.edu/sponsoredresearch/ under “Forms and Resources.”

Uniform Guidance (UG): Federal grants are maintained in compliance with the Office of Management and Budget’s (OMB) 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, commonly called Uniform Guidance. The Uniform Guidance is a government wide framework for grants management, and provides an authoritative set of rules and requirements for Federal awards.

V. Cross-Referenced Policies

Policy 12-1 Grant Application Process

SPON-003 Grants Incentive (Indirect Cost Distribution)

SPON-004 Gift or Grant Determination

SPON-005 Cost Sharing Requirement (Cash or In-Kind Matching)

Promoting Objectivity in Research—Financial Conflicts of interest in Research for Public Health services (PHS) Investigators

VI. Consequences of Non-Compliance

Grant awards that do not comply with the policy outlined above risk termination of the grant award by the College or granting agency. Faculty and staff members may incur personal and financial liability for lack of compliance with grant rules and requirements.

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