Account Monitoring begins when a sponsored project account is set up and continues throughout the life of the award. For proper monitoring of accounts, an initial review of the budget and award documents should be completed at award notification. Review the budget "as submitted" and the award documents, including the "awarded budget". Knowing the details will assist in determining what expenses are allowable and not - as well as which require prior written approval. In addition, the award notice advises of administrative details, such as the allowability of no-cost extensions. Programmatic requirements, such as changes in key personnel or scope of work, project milestones, and reports to be delivered are also contained within the award document. Once all is reviewed, the unit will be in a better position to work with the PI to establish a plan of work.
Units typically assist the PI with account monitoring to ensure accounts are expended properly, to review for changes which may require action, and to avoid overexpenditure. However, ultimately, it is the PI who is responsible for the management of his or her project. This includes expending the sponsor’s funds according to the sponsor’s requirements, 2 CFR Part 200 (where federal funds are involved) and ASU's policies (RSP 103 and FIN 203). Any deficits that result become the responsibility of the PI’s unit.
The Fiscal Oversight Team performs limited 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.
Additional funds coming into a sponsored project could be the result of a revision/supplement. The additional funds must be processed in ERA – using current Facilities & Administrative (F&A) practices, current Employee Related Expenses (ERE), and current tuition rates. See the Additional Funds for a Sponsored Project page for further information.
When an ASU individual will receive funds in excess of their institutional base salary, the unit will complete Additional Pay Web Form for earn codes HNR, ICS, ISP, DPA, or STI-exempt only. Additional pay must have sponsor approval and will need to meet the following criteria:
- Additional pay is for work that is above and beyond the employee’s regular ASU duties and is ordinarily provided outside normal work hours.
- Employee is not named as an investigator on the project.
- Employee’s institutional base salary is not being funded by the project.
- Employee will perform the work for a department, center or academic unit other than the employee’s home department; OR Employee will perform the work at a separate or remote operation.
For steps to processing Additional Pay Web Form, review EP-130.
The After-the-Fact Review Report, which replaces the former ASU effort reporting certification system, was developed by OKED to meet the requirements of compensation review in 2 CFR 200.430(i) Standards for Documentation of Personnel Expenses which states that
Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
This report, in combination with ASU’s existing strong internal control system, provides a less cumbersome, more intuitive means for ensuring compliance with OMB requirements.
When an ASU individual will receive funds designated to HSG, MOV, SDM, or ETR earn codes, the department will send a written justification to the OKED Fiscal Oversight Team at SPNmonitoring@asu.edu for review and approval. Allowance pay must have sponsor approval.
- Reasonable; and
- Allocable to the project; and
- Given consistent treatment by use of generally accepted cost accounting principles; and
- Conform to 2 CFR Part 200 (Uniform Guidance) and any limitations or exclusions set forth by the sponsored award.
For additional information about consistent treatment of costs, see the Cost Accounting Standards (CAS) Sitelet.
Projects that are incrementally funded and only authorized to spend during a specified period may request at-risk status for time and/or funding to continue work without interruption, pending receipt of a modification.
For steps to take to make a request, see EP-130.
- Reconcile project expenses, resolving and removing all encumbrances.
- Determine whether a carryover will be requested and inform the assigned GCO.
- Submit an Award Change Request in ERA to request carryover approval. Make sure to include a technical justification, budget and budget justification for the carryover funds.
NIH has specific steps which must be followed. For more information see EP-130
Generally sponsors consider the PI, Co-PIs, and in some cases other faculty investigators on the project to be Key Personnel. Key Personnel are those individuals on the project who make substantive decisions about the design, conduct or reporting of research for this proposal. This will normally not be a student, post-doc, consultant, technician or staff member, though the possibility exists in limited circumstance where that specific individual's unique skills are pivotal to the project. Changes in Key Personnel usually require prior sponsor approval before making the change.
For additional information about making changes to Key Personnel, please see WI-EP-130.
In general, the PI may make changes in the methodology, approach, or other aspects of the project objectives. However, sponsor approval is required for changes in scope, direction, type of training, or other areas that constitute a significant change from the aims, objectives or purposes of the approved project. The PI should discuss changes with the program officer at the sponsoring agency to determine whether or not their approval is required. Some examples of changes in scope might include:
Change in the specific aims approved at the time of award
Substitution of one animal model for another
Change from the approved use of animals or human subjects
Shifting the research emphasis from one area to another
Applying a new technology, e.g., changing assays from those approved to a different type of assay
Issuing a subaward to another organization, including another university
Change in Key Personnel
Significant rebudgeting as indicated in the sponsor's award guidelines/document
If it is determined that sponsor approval is required, complete and submit an Award Change Request in ERA.
Cost sharing is the portion of the total project costs not paid for by the sponsor but rather is covered by ASU and/or third parties. For detailed information about this topic, visit the Cost Sharing Sitelet.
A cost transfer is defined as an after-the-fact reallocation of a cost (expenditure). Transfers may involve moving funds from one account to another or revising an object/subobject code within the same account. In either case, the request will be carefully scrutinized to ensure the necessary paper trail is available for audit and to allow for updates to unit practices to avoid such errors in the future. Examples of times when a cost transfer may be appropriate include:
Correction of clerical errors
Reallocation of salary and ERE (fringe) to reflect actual effort (payroll redistribution)
Transfers between sub-allocations on the same sponsored project (non payroll transfers)
Transfer of pre-award costs from a local account
Costs benefiting more than one project
Clearing potential or actual overruns
Visit the Cost Transfer Sitelet for additional information.
Modifications (aka Amendments) are used to change the terms and conditions of an award, including supplements, incremental funding, changes in key personnel or scope of work, rebudgets, and other items which impact the administration of the award. Only ORSPA has the authority to execute modifications/amendments.
When circumstances will prevent a Principal Investigator (PI) from achieving his/her project objectives by the award expiration date and awarded funds are still available, the lead PI should consider requesting a no cost extension (NCE). This will allow the PI more time to complete the scope of work without requesting additional funds from the sponsor. The fact that funds remain in a grant is not in and of itself an appropriate justification of a no cost extension. The extension must be needed to complete the objectives of the grants.
For instructions on the process for requesting no cost extensions, please see WI-EP130.
Rebudgeting, or changing the way award funds are spent, may require prior approval by the funding agency or under 2 CFR Part 200 (Uniform Guidance). For example, NSF requires prior approval to transfer funds out of participant support costs. Approval to rebudget, if required, must be requested of the sponsor in writing, under the signature of the AMT GCO.
The award document, 2 CFR Part 200 (Uniform Guidance), and the AMT GCOs can help interpret whether agency permission is needed to rebudget.
Compare original budget approved by sponsor with the proposed budget.
Review sponsor guidelines (award document, award guidelines) and 2 CFR Part 200 (where federal funds are involved) and ASU policies to determine if the request is allowable and if prior sponsor approval is required. Contact the assigned AMT GCO if unsure.
Initiate rebudget of project funds to address discrepancies between original budget and proposed budget using the Award Change Request Budget Template.
Ensure that any F&A funds due or freed up as a result of the budget are captured in the proposed budget.
See WI-EP-130 for instructions on how to process a rebudget request.
When PIs leave ASU for another institution, they often transfer their projects to the new institution. For additional information about transferring projects to another institution, see Departing Faculty on Sponsored Projects page.
For new faculty transferring awards into ASU, refer to Transfer of Sponsored Projects to ASU page.
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