The Fiscal Oversight Team performs targeted expenditure monitoring based on the requirements unique to Sponsored Accounts.  Targeted training to enhance understanding and compliance is provided based on opportunities identified through monitoring, or by request.

In particular, expenditures identified as Cost Accounting Standards exception items are regularly reviewed. Guidance related to CAS exceptions can be found on the CAS page.

Requests to review documentation in support of specific sponsored expenditures will not require providing any additional documentation beyond what is generated at the time of expenditure. Fulfilling documentation requests from Fiscal Oversight should simply require transmitting existing documentation already on file.

Expenditure monitoring task overview 

FOT currently conducts several recurring expenditure monitoring tasks designed to ensure compliance with Regular monitoring is an additional safeguard to help ensure compliance with the Office of Management and Budget Uniform Guidance 2 CFR Part 200 and other applicable regulations governing sponsored activity. FOT’s current expenditure monitoring tasks are as follows: 

Cost center level expenditure monitoring (ongoing)

Cost centers with sponsored expenditures are sampled periodically for expenditure monitoring. The review confirms overall allowability of expenses with special focus on the following high-risk expenditures:  

• Capital equipment 
• Materials and supplies purchases in excess of $5K purchased in last 90 days of project
• Foreign Travel 

Grants with non-grant spend object class charges (monthly)

There are certain spend categories that are normally not allowed on sponsored projects such as Transfers Out, Costs of Goods Sold, Administrative Services Charge, etc. Using the Workday report Expenditure Monitoring – Grants with Non-Grant Spend Object Class, FOT identifies university-wide pending and posted expenses that have been tagged with a non-grant spend category. If report returns any transactions with non-grant spend categories, FOT will reach out to the transaction initiator and grant manager to request:  

1. for expenditure to be recoded or  
2. for expenditure to be removed from grant 

Prohibition on telecommunications and video surveillance equipment (monthly)

Per, §200.216 Prohibition on certain telecommunications and video surveillance services or equipment, grantees must prevent purchases with prohibited companies and their subsidiaries. 

Using the research analytics report Foreign Risk Supplier Payments, FOT identifies university-wide posted purchases that have been made to prohibited suppliers. If report returns any transactions with prohibited supplies, FOT will reach out to the transaction initiator and grant manager to request the purchase to be canceled/removed from the grant account. 

Pre-award spending (quarterly)

Pre-award spending is the ability to incur expenditures prior to the official Award Start Date. Some Federal awards afford grantees expanded authorities to charge pre-award expenditures up to 90 days prior to the start of the project without prior sponsor approval. Any award with pre-award spending should have a designated “Pre-Award Spending Date” in ERA to document the use of expanded authority or sponsor prior approval.  

Using the Workday report, Expenditure Monitoring – Transactions Outside of Grant Period, FOT will identify awards that have posted expenditures before the ERA Award Start Date. FOT will then verify that those awards have a “Pre-Award Spending Date” in ERA.  

Units managing awards with pre-award expenditures but without a preaward spending date in ERA will be prompted to: 

1. submit an award change request to document expanded authorities, or  
2. submit an award change request to request sponsor prior approval. 

Relocation costs of employees (annual)

Per §200.464 Relocation costs of employees, relocation costs posted to a grant account must be refunded if employee resigns within 12 months for reasons within their control.  

Using the Earnings tab of the Fiscal Oversight Expenditure Monitoring dashboard, FOT will identify all employees for the previous fiscal year who received additional pay with the earn code “MOV”. Once the list is populated, using PeopleSoft we will verify the following:  

1. if employee is still an active employee at ASU,  
2. verify position mapping for the first 12 months of employment,  
3. if employee is no longer in the same position or has departed the university, relocation expenses will be requested to be moved off the grant.  

Grant accounts without principal investigator (monthly)

PIs have primary responsibility for the management of their sponsored projects in accordance with federal, state, university and sponsor requirements (RSP 103).

FOT monitors the Grant Role Error – Lead PI Missing WD report for risk due to the absence of a PI on an active sponsored award. Departments are notified of the need for an immediate replacement of the PI to backfill the vacant role on the grant account.

Burn rate analysis (quarterly)

A burn rate is the comparison of the percentage of budget that has been spent compared to the percentages of time that has passed. FOT identifies high risk burn rates where differences between these two percentages are greater/less than a positive/negative 25%. High risk burn rates can help identify performance challenges that, when caught in time, can be remedied. 

Using results of the Budget to Actuals – Grant Summary, FOT samples high burn rates and reaches out to the grant manager to identify appropriate next steps. 

Spend on non-budgeted categories (quarterly)

There are certain types of expenses that would not be expected on a grant if there is no budget for that category, such as personnel, participant support costs, capital equipment and F&A. 

Using the Expenditure Monitoring – Grant Budget Categories and Expenditure Monitoring – Grant Summary Expenses reports, FOT reviews grants for expenses on $0 budget summary categories and contacts grant managers (for direct costs) and AMT GCOs (for F&A) to make appropriate corrections. 

Contact information

For further information about routine monitoring and oversight or to clarify any specific review requests received, please contact the Fiscal Oversight Team.