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Sponsored Account Monitoring & Compliance Training

Last updated: 08/30/2022 - 8:45am

Sponsored Account Monitoring & Compliance Training

The Fiscal Oversight Team (FOT) 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 (CAS) exception items are regularly reviewed. Guidance related to CAS exceptions can be found in the CAS Sitelet.

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: 

 

Expenditure Monitoring Task 

Task Description 

Frequency 

Cost Center Level Expenditure Monitoring 

All cost centers with sponsored expenditures are sampled for expenditure monitoring twice per year. The period of review covers one fiscal quarter. The review confirms overall allowability of expenses with special focus on the following high-risk expenditures: 

 

  • Office Supplies 

  • Postage, Phones, Utilities 

  • Food, Dues/Memberships 

  • Student and Participant Support 

  • Capital Equipment 

  • Materials & Supplies purchases in excess of $5K 

  • Purchases in the last 90 days of the project 

  • Travel 

 

Ongoing 

Grants with Non-Grant Spend Object Class Charges 

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 

Monthly 

Prohibition on telecommunications and video surveillance equipment

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 cancelled/removed from the grant account. 

 

Monthly 

Pre-Award Spending 

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. 

Quarterly 

Relocation Costs of Employees 

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 same position or has departed the university, relocation expense will be requested to be moved off the grant.  

Annual 

Burn Rate Analysis 

A burn rate is the comparison of the % of budget that has been spent compared to the % 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 a WD Worksheets version of Budget to Actuals – Grant, FOT samples high burn rates and reaches out to the grant manager to identify appropriate next steps. 

Quarterly 

Spend on Non-Budgeted Categories 

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. 

Quarterly 

 

Contact Information

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

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