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Office of Grants and Contracts Post-Award Handbook

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Office of Grants and Contracts Post-Award Handbook Powered By Docstoc
					                                 Office of Grants and Contracts Post-Award Handbook
I.         Introduction to Post-Award Administration ...................................................................................4
II.        Promptness .................................................................................................................................5
III.          Compliance with Agency, State, and University Regulations ......................................................5
IV.           Financial Information Compliance Monitoring ..........................................................................6
      a.      Salary .....................................................................................................................................6
      b.      Contracted Services .................................................................................................................7
      c.      Sub-awardees/Subcontracts ......................................................................................................7
      d.      Travel .....................................................................................................................................7
V. Responsibilities of the OGC Post-Award ......................................................................................7
VI.           Responsibilities of the PI/PD:...................................................................................................7
VII.          Expenditure Guidelines and Exceptions ....................................................................................8
      a.      General ...................................................................................................................................8
      b.      Advertising and Public Relations ..............................................................................................8
      c.      Alcoholic Beverages................................................................................................................8
      d.      Alterations and Renovations .....................................................................................................8
      e.      Alumni Activities ....................................................................................................................8
      f.      Bad Debts ...............................................................................................................................8
      g.      Commencement or Convocation Costs ......................................................................................8
      h.      Contingency Provisions ...........................................................................................................8
      i.      Charitable Contributions and Donations ....................................................................................8
      j.      Books and Periodicals ..............................................................................................................8
      k.      Consultant Services .................................................................................................................9
      l.      Cost Overruns on Other Grants .................................................................................................9
      m. Entertainment ..........................................................................................................................9
      n.      Office Equipment ....................................................................................................................9
      o.      Food .......................................................................................................................................9
      p.      Goods or Services for Personal Use of Employees ...................................................................10
      q.      Housing and Personal Living Expenses ...................................................................................10
      r.      Lobbying ..............................................................................................................................10
                                                                                                                                                         1
   s.      Memberships.........................................................................................................................10
   t.      Office Supplies......................................................................................................................10
   u.      Proposal Costs.......................................................................................................................10
   v.      Recruiting Costs ....................................................................................................................10
   w. Retroactive Cost Transfers .....................................................................................................10
   x.      Selling and Marketing Costs...................................................................................................11
   y.      Student Activity Costs. ..........................................................................................................11
   z.      Telephone .............................................................................................................................11
VIII. Direct Costs ..........................................................................................................................11
IX.        Managing Your Grant ............................................................................................................11
   a.      Acquired Goods and Services (AGS) ......................................................................................11
   b.      Additional Criteria for Determining Direct Costs .....................................................................12
   c.      Budget Revisions...................................................................................................................12
   d.      Carryover of Unobligated Funds .............................................................................................13
   e.      Communication Costs ............................................................................................................13
   f.      Consultants/Contractors .........................................................................................................13
   g.      Copy Charges........................................................................................................................14
   h.      Cost Sharing or Matching.......................................................................................................14
   i.      Cost Transfers .......................................................................................................................16
   j.      Course Release(s) and Redirects .............................................................................................17
        1. Course Release ......................................................................................................................18
        2. Redirects...............................................................................................................................18
   k.      Disallowable Expenditures and Overdrafts ..............................................................................18
   l.      Equipment Management ........................................................................................................19
   m.       Export Control ......................................................................................................................19
   n.      Facilities and Administrative (Indirect) Costs ..........................................................................22
   o.      Fixed-Price Contracts.............................................................................................................23
   p.      Grant Residual Funds.............................................................................................................24
   q.      Hiring Personnel....................................................................................................................25
   r.      Leave Benefits.......................................................................................................................25
   s.      Lecture/Performance Agreement ............................................................................................25
                                                                                                                                                   2
     t.         Memberships, Subscriptions, and Professional Activity Costs...................................................25
     u.         No-Cost Extension.................................................................................................................25
     v.         Overtime for Employees ........................................................................................................26
     w. Pre-Award Costs ...................................................................................................................26
     x.         Procurement Services.............................................................................................................26
     y.         Procurement Cards ................................................................................................................26
           1. Prior Approval P-Card Policy/Process for Grants and Contracts ................ Error! Bookmark not
           defined.26
     z.         Professional Service Costs .....................................................................................................27
     aa.           Program Income ................................................................................................................27
     bb.           Recommended Purchasing Deadlines for Grants ..................................................................28
           1.      KSU P-Card Deadlines.......................................................................................................28
           2.      KSU AGS/Misc. Deadline ..................................................................................................28
           3.      KSU Travel Expense Statement Deadline ............................................................................28
           4.      Grant-Specific Deadline(s). ................................................................................................28
     cc.           Salaries and Wages ............................................................................................................28
     dd.           Summer and Maymester Payroll .........................................................................................29
     ff.           Space Rental .....................................................................................................................29
     gg.           Stipends ............................................................................................................................30
     hh.           Subcontract and Subgrant Effort .........................................................................................30
     ii.            Supplies ............................................................................................................................30
     jj.          Time and Effort Reporting ..................................................................................................31
     kk.          Time-Limited Appointments ...............................................................................................33
     ll.          Travel................................................................................................................................33
     mm.           Utility Services ..................................................................................................................33
     nn. When Administrative and Clerical Salaries and Staff Benefits Can Be Charged as Direct Costs ...33
     oo.           Closeout of Agreements .....................................................................................................34
X.         Audit Matters and Reports .........................................................................................................35
     a.         General .................................................................................................................................35
     b.         Focal Point for Audit Matters .................................................................................................35
     c.         Grants Accounting Administration Representation ...................................................................35

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  d.   Right of Access .....................................................................................................................35
  e.   Exit Conference.....................................................................................................................35
  f.   Audit Response .....................................................................................................................36
  g.   Cost Disallowance .................................................................................................................36
Appendix A: Closeout Checklist for P. I.

Appendix B: Grants and Contracts Responsibility Matrix

Appendix C: Research Terms and Conditions Prior Approval and Other Requirements Matrix

Appendix D: Administrative Action Request Form




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                          I. Introduction to Post-Award Administration
OGC is available for advising and/or referring to appropriate University officials on matters
relating to federal and state laws, Board of Regents regulations, as well as University rules,
regulations, and policies pertaining to fiscal management of contracts and grants. The Office is
responsible for ensuring that the business interests of the University are protected throughout the
operation of such agreements. In addition, the Office helps to ensure that the University
complies with all provisions of contracts, grants, and agreements entered into with outside
companies or agencies.
The OGC is responsible for maintaining auditable records in support of direct and indirect
charges to contracts and grants, as well as for preparing and filing fiscal reports required by
grantor agencies. OGC is responsible for billing and collecting costs incurred on cost
reimbursement contracts and for requesting funds related to said contracts.

OGC is committed to providing accurate and timely reports so that project directors can assess
actual performance against awarded and budgeted funds.
The OGC post-award staff follows:

Shannon West
Assistant Director
Phone: (770) 499-3377
skinman@kennesaw.edu

Candis Lobik Dickson
Accounting Professional
Phone: (770) 423-6973
clobik@kennesaw.edu

Anna McCoy
Accounting Professional
Phone: (770) 423-6984
amccoy6@kennesaw.edu

Debbie Shook
Accounting Professional
Phone: (770) 423-6974
dsy6649@kennesaw.edu\


                                             II. Promptness
Upon acceptance of a sponsored project, the University is responsible for promptly pursuing the
research, training, or public service called for by the agreement.

                  III. Compliance with Agency, State, and University Regulations
Project directors and Principal Investigators have primary responsibility for conducting the
sponsored effort in accordance with award terms and conditions and within the funds allocated
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for such effort. They also are responsible for the programmatic direction of the research project
and for initial authorization of all expenditures charged to the award budget. The Principal
Investigator is ultimately responsible for expending funds in compliance with all agency, state,
and University regulations.

Deans, directors, and department heads have a corollary responsibility for assuring that all
sponsored programs conducted within their jurisdictions conform to the guidelines established by
the Southern Association of Colleges and Schools and are consistent with agency, state, and
University policies.

The Office of Grants and Contracts is responsible for acting as a liaison between the project
directors and the agency regarding fiscal matters. This includes financial reporting and financial
compliance monitoring.

                          IV. Financial Information Compliance Monitoring
The Office of Grants and Contracts has the primary responsibility for providing the Principal
Investigator with financial information necessary to effectively manage a sponsored effort and to
assure that all parties comply with the financial terms of the agreement.

The Principal Investigator is responsible for making prudent use of funds awarded for a
sponsored project to ensure that expenditures are appropriate and directly relate to the budget and
intent of the award and comply with applicable University, state, federal, and agency directives.

The Office of Grants and Contracts monitors expenditures to ensure compliance with applicable
rules, regulations, and directives. Many types of expenditures related to sponsored projects are
handled in the same manner as expenditures for other fund sources and are subject to the same
routine processing, reviews, approvals, and other controls. However, some types of expenditures
related to sponsored projects require a different level of scrutiny to assure fiscal compliance with
the award. The OGC must approve them prior to processing. They include the following:

      Salaries and Wages
      Contracted Services
      Subcontracts and Sub-awards
      Foreign Travel
      Food
      Scholarships

Following are the specific forms to be used or references to the appropriate offices to be
contacted in order to request expenditures be made.

a. Salary
    For appropriate staff employee documents, please contact Human Resources.
    For appropriate faculty and administrative staff employee documents, please contact the
      Office of the Provost.
    For appropriate student payroll documents, please contact the Payroll Office.


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      For appropriate work-study student payroll questions, please contact the Office of
       Financial Aid.
      For appropriate graduate assistantship student documents, please contact the Graduate
       College.

b. Contracted Services
    Contact Procurement

c. Sub-awardees/Subcontracts
    Grants and Contracts

d. Travel
    Business Services

                           V. Responsibilities of the OGC Post-Award
   1. Issue invoices to funders
   2. Prepare financial reports for the awarding agencies
   3. Set up grant budgets and assign account numbers
   4. Refer the P.I. to other University offices, as needed
   5. Remain current on federal, state, and University policies related to grants
   6. Review and approve the financial aspects of agreements, contracts, and grants
   7. Oversee financial compliance related to award terms and conditions
   8. Train faculty and staff in research administration regulations and procedures
   9. Serve as a liaison with auditors on financial matters
   10. Implement approved budget revisions
   11. Review and approve transactions prior to spending
   12. Initiate draw downs for all sponsored programs accounts

                                  VI. Responsibilities of the PI/PD:
   1. Attend a post-award meeting with OGC post-award personnel to review appropriate
       regulations and receive budget information for new awards
   2. Review monthly reports and contact OGC regarding any discrepancies
   3. Approve all grant expenditures
   4. Ensure all grant expenditures are reasonable, allowable, and solely allocable to the grant
   5. Provide records in support of cost share, matching or in-kind requirements, and time and
       effort reporting
   6. Know the award terms and conditions
   7. Know reporting requirements
   8. Know patent, invention, and technology transfer issues
   9. Notify the OGC of any change in P.I. or other grants personnel status
   10. Provide information about program performance to the OGC when it is needed for
       preparation of financial reports
   11. Begin incurring expenses immediately and on a regular basis once an account number is
       assigned to a project
   12. Request budget revision through the OGC
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     13. Provide the OGC with the course release schedule
     14. Ensure that all grant expenditures comply with University policies and procedures
     15. Work with Human Resources to hire/terminate personnel

                          VII.    Expenditure Guidelines and Exceptions

a. General
Most federal and non- federal sponsoring agencies or organizations issue their own policy
guidelines and directives defining acceptable costs for purposes of their program(s). Despite a
great deal of commonality as to content, there are sufficient variations in policies to make it
impractical to issue and maintain a policy compendium. Individual agency or organizational
directives must be consulted for authoritative guidance.
The purpose of this section is not to repeat definitions of cost elements, but rather to provide
clarification, guidance, or references as to University policy. Additionally, special
considerations or problems will be highlighted.

The following list covers unallowable costs specified in Section J of OMB Circular A-21 and
costs that are normally treated as Facilities and Administrative Costs. This is a quick reference.
This specific wording in A-21 should be referenced when greater detail is needed
(http://whitehouse.gov/omb/circulars/a021/a21_2004.html).

b. Adve rtising and Public Relations

c. Alcoholic Beverages
Costs of alcoholic beverages are unallowable unless included in the agency-approved budget.

d. Alte rations and Renovations
Such costs are allowed only in exceptional cases and are subject to specific sponsor guidelines
and limitations. Alterations and renovations are normally authorized only for specialized facility
requirements and not for general purpose space such as administrative offices.

e. Alumni Activities

f. Bad Debts

g. Commence ment or Convocation Costs

h. Contingency Provisions

i.   Charitable Contributions and Donations

j. Books and Pe riodicals
Customarily, such items are allowable as a direct cost required for the conduct of a project.
However, one major federal sponsor, Public Health Service (PHS), is concerned with the need
for such items where library service is available. As PHS requirements and perspectives tend to

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influence federal audit requirements, it is recommended that requisitions for books or periodicals
to be charged against federal projects be accompanied by a brief explanation on the requisition as
to why it is not feasible to obtain them through normal library service. A brief justification on
the requisition will likely preclude questions of relevance and necessity during any audit review.

k. Cons ultant Services
Proposed consultant charges are subject to particular scrutiny by a sponsor. The federal
government permits such charges if budgeted in advance and if it can be documented that such
services are essential and will be obtained from the most qualified person at reasonable and
normal rates. All consulting services are to be obtained in concurrence with established
University policy.

l. Cost Overruns on Other Grants
Cost overruns on one grant may not be charged to another grant. This includes, but is not limited
to, institution’s contributed portion of cost-sharing agreements or any under-recoveries through
negotiation of flat amounts of indirect costs.

m. Entertainment
Costs of amusements, social activities, entertainment, and incidental costs related thereto are not
allowed.

n. Office Equipment
Purchases of specialized equipment are normally allowable with approval from the sponsoring
agency. Purchases of general office equipment and furnishings, such as desks, chairs, tables,
etc., will generally not be approved by a federal agency.

Whenever practical, equipment already in possession of the University will be utilized to meet
research needs. Project funds are normally used to pay for authorized equipment acquired
sufficiently in advance of the ending date (prior to last 90 days) of the project period to be
effectively used on that project. Purchases of equipment not meeting the effective utilization
test, particularly if there is not a follow-on or continuation award, are usually questioned by
auditors and generally result in a cost disallowance or exception.

o. Food
Food may be purchased from grant funds if it is included in the budget approved by the funding
agency at award or if the Principal Investigator receives written approval from the funder after
the award is received.




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p. Goods or Services for Personal Use of Employees

q. Housing and Personal Living Expenses

r. Lobbying

s. Membe rships
Costs of membership in any country club or social or dining club or organization are
unallowable. Institutional memberships in professional organizations and subscriptions to
technical periodicals are normally treated as an F&A cost.

t. Office Supplies
These items of cost are allowed as facilities and administrative costs. Costs include those
incurred in support of routine administrative activities associated with instruction, public service,
research, and other institutional activities. This category includes, for example, computers
(under $5,000), printers, monitors, digital cameras, fax machines, printer paper, toner cartridges,
pens, pencils, legal pads, clips, rubber bands, post- in notes, notebooks, binders, folders, CD-
ROMs, and departmental stationery. The only exceptions are those wherein the purchase of the
supplies is extensive in nature, can be specifically identified with the project, and meets the
definition of a direct charge adequately justified in the budget at proposal submission.

u. Proposal Costs
Proposal costs for both successful and unsuccessful bids are treated as F&A costs.

v. Recruiting Costs
Recruiting costs are normally treated as F&A cost. This will include visa application
fees/expenses.

w. Retroactive Cost Transfers
The federal guidelines for cost transfers state, ―Any cost allowable to a particular research
agreement may not be shifted to other research agreements in order to meet deficiencies caused
by overruns, to avoid restrictions, or for other reasons of convenience.‖ As a result, the Office of
Grants and Contracts must screen all requests for transfer of expenditures to ensure compliance
with these regulations. Federal regulations normally allow such transfers only within ninety (90)
days of the original encumbrance.
When applying for a retroactive costs transfer, send a memo to the Director of Grants and
Contracts requesting the transfer. The memo must contain all details pertaining to the transfer
and a copy of the document showing the expenditure. In addition, a full explanation and reason
for the transfer should be given.




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x. Selling and Marketing Costs of any products or services of the institution are unallowable.

y. Student Activity Costs incurred for intramural activities, student publications, student clubs,
   etc. are unallowable.

z. Telephone
Installation charges, monthly use charges, local access calls, pagers, etc. are considered F&A
costs and should not be charged directly to sponsored accounts, except in the rarest
circumstances. The basic telephone line charge and local calls may be charged directly to a
sponsored project when a separate, dedicated telephone line is necessary solely for the
performance of a sponsored project. Long distance charges are allowable.

                                        VIII. Direct Costs
All costs must be charged in a timely manner and must be:

      Allocable: The cost must have a direct benefit and be directly attributable to the project
       or activity being performed.
       ―If a cost benefits two or more projects or activities in proportions that can be determined
       without undue effort or cost, the costs should be allocated to the projects based on
       proportional benefit. If a cost benefits two or more projects or activities in proportions
       that cannot be determined because of the interrelationship of the work involved, … the
       costs may be located or transferred to benefitted projects on any reasonable basis…‖
       (OMB Circular A-21, Section C.4.d(3).
      Allowable: Costs must be allowed by University policy, sponsor policies, the project’s
       Notice of Contract/Grant Award, and federal policy (OMB Circular A-21).
      Reasonable and necessary for the performance of the project.

Any expense that does not meet all of these criteria cannot be charged to the externally
sponsored project, in accordance with accounting practices of the University.

University policy, in accordance with OMB A-21, defines costs as allowable or unallowable.
Allowable costs must be treated as direct or F&A costs. There may be exceptions when OMB
guidelines permit the direct charging of costs normally treated as F&A.

                                     IX. Managing Your Grant

a. Acquired Goods and Se rvices (AGS)
All AGS requests against a sponsored grant or contract must be approved by the Project Director.
This approval certifies that the cost is allowable and solely allocable to the grant. All costs must
conform to any limitations or exclusions in the sponsored agreement as to types or amounts of
cost items.

All backup documentation for AGS requests must contain the following information (as
applicable to the type of expense):

With every expense, you should have:
       An itemized/detailed receipt/invoice
                                                                                                 11
       Purpose and how the expenses relate to your grant

If applicable to the type of expense:
        Name of Event
        Date, time, and location of event for which this purchase was made
        List of attendees (participants) at event
         Agenda for the event/workshop or other supporting documentation
        Prior approved contractual, subcontract, lecture agreement, etc…

[Per OMB Circular A-21 Section C
http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html#c]

 For complete AGS guidelines/instructions, please visit
https://financialservices.kennesaw.edu/files/Forms6/procurement/business_services_agss_user_g
uide.pdf.

b. Additional Crite ria for Determining Direct Costs
A cost must be included in the awarded budget. If a cost requires institutional and/or sponsor
prior approval after the award is made, the approval(s) must be secured before the cost is
incurred.

c. Budget Revisions
There is considerable variation in sponsor policies relative to approval authorities for budget
revisions. Accordingly, sponsor agency guidelines and award terms must be consulted when
revisions are contemplated. Budget revisions sho uld be based upon the financial plan and cost
trends for the award budget period involved. To the extent possible, budget revisions should
reflect all necessary reallocations of resources that are foreseen through the end of the budget
period. Revisions solely for the purpose of coping with near-term problems (e.g., a $35.00
overdraft in the supplies category) should be avoided. If resources in all categories are already
substantially committed to known requirements, a budget revision can only serve to defer, not
resolve, a financial problem. In such cases, reduction of the project scope and effort may be the
only viable solution. Another, but less likely, possibility may be additional funding by the
sponsor.

If prior sponsor approval is required for a budget revision, an OGC accounting professional will
draft a letter to the sponsor. A draft of the letter to the sponsor will be emailed by the assigned
accounting professional to the Principal Investigator for review prior to release to the sponsor.

Budget requests not requiring sponsor approval are normally processed within a few days of
receipt by the Office of Grants and Contracts. Complete the Administrative Action Request
(Appendix D) and send to the OGC.

To determine if budget revisions require sponsor approval, consult your grant terms and
conditions and the matrix in Appendix C.



                                                                                                  12
When agency approval is required and received, the budget revision will be entered into the
Financial Accounting System by the assigned accounting professional and the Principal
Investigator so notified.

d. Carryover of Unobligated Funds
Carryover should be requested to support one-time activities that align with the grantee’s
existing goals and objectives. For awards not subject to expanded authority, recipients must
request carryover of unobligated funds from one budget period to the next. When requesting a
carryover, keep the following in mind:

      The carryover request should be completed only after the OGC has determined the
       unobligated balance for the applicable budget year.
      The carryover request must be submitted at least 120 days before the end of the program
       year in which the funds are being requested.
      Approved carryover funds must be obligated in the year in which they are awarded.
      Carryover funds are intended to cover only prospective costs, not costs already incurred
       by the recipient.
      Funds support one-time activities. Approval for one-time activities does not constitute
       automatic approval for funding these activities in the future.

Required Documentation:

      Overall budget table indicating current funding levels for each budget category
       (personnel, fringe, travel, etc.) and carryover funds requested for each category
      Budget request and detailed justification outlining the activities that will be completed
       using carryover funds, how the activities relate to the existing and approved work plan,
       and a cost breakdown for each activity (ex. Unit cost per item X number of items needed
       = total cost). Budgets should be rounded to the nearest dollar; do not include cents.
       Ensure that all columns sum correctly.

Please see the matrix in Appendix C and review your grant award terms and conditions to
determine if carryover of unobligated funds is permitted. If allowed, complete the
Administrative Action Form in Appendix D and forward it to the OGC.

e. Communication Costs
Only in specific circumstances may cell phone costs be charged directly to a sponsored project.
These costs should be approved in the award budget.

f. Cons ultants/Contractors
The Office of Grants and Contracts (OGC) and Chief Operations Officer are the only units on
campus authorized to execute an agreement with consultants whe n sponsored funds are to be
used. This includes any ―company‖ or corporation formed by an individual who is the sole
stockholder. Procurement Services handles all consultant agreements when the consultant is not
named in the proposal. [Per OMB Circular A-21 Section J General provisions for selected items
of cost #37 http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html]
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If a grant award has predetermined the status of a consultant (provides advice only) or
independent contractor (provides services or products), then no additional status determination
will need to be made. Consultants who are specifically named in a grant will be required to
complete an OGC Request for Consultant/Contractor form and provide a resume. If a
consultant is not specifically named in a grant and the agreement is $5,000.00 or greater,
but a description of work is stated in the grant, then a Sole Source form must be completed
by the Project Director and submitted with the OGC Request for Consultant/Contractor
form and resume.

If a grant award has not predetermined the status of a consultant or independent contractor, then
additional determination of status will be made using IRS guidelines. Procurement Services,
Business Services, and Human Resources will make this determination jointly.

All requests to hire a consultant should be made using the OGC Request for
Consultant/Contractor form. As noted on the form, requests to hire a consultant must be fully
approved by the OGC prior to work beginning. NOTE: ACTIVE KSU EMPLOYEES CAN
NOT BE HIRED AS CONSULTANTS/CONTRACTORS.

To initiate payment of a consultant/contractor, an AGS request should be submitted along with
an invoice and a copy of the signed contract.

g. Copy Charges
If your grant allows for on-campus, grant-related copy charges in the budget, the Project Director
should contact the Associate Director of Print Copy Services, x2344, to request a copy code be
created for direct copy charges to the grant. The Project Director must provide the grant name
and grant speed chart number for the code to be established. At the close of the grant award, the
Project Director is responsible for notifying Print Copy Services to terminate the grant copy
charge code. If this code is used beyond the grant end date, the copy charges will default to the
Project Director’s home department. [Per OMB Circular A-21 Section C
http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html#c]

h. Cost Sharing or Matching
Cost sharing or matching in grants and contracts are terms that are used interchangeably. Cost
sharing can either be imposed by a sponsor as a condition necessary to receive their support, or it
can be volunteered on the part of the University to demonstrate its commitment to a project.
Once a proposal containing cost sharing, be it imposed or volunteered, is accepted by a sponsor,
it is considered binding upon the University and requires written approval from the sponsor to
change. Cost sharing obligations must be kept within reason and must be capable of being
fulfilled from acceptable resources available to the Principal Investigator, the chair of his/her
department, dean of his/her academic unit, director of associated center/institute, the Vice
President for Research, or the Provost.

Once an award is accepted by the University, the Principal Investigator is responsible for
ensuring that any cost sharing commitments are met and that all necessary documentation is
provided to the Office of Grants and Contracts. Cost sharing or matching expenditures incurred


                                                                                                 14
or services rendered must occur during the period of the award and are subject to the same
sponsor guidelines and regulations.

Cost sharing or matching is that portion of the project or program costs not paid by the sponsor.
There are three types of cost sharing:

      Mandatory cost sharing is required either by federal statute or by the established policy of
       the sponsor.
      Voluntary committed cost sharing is in excess of any mandatory cost sharing. It is
       volunteered to demonstrate the University commitment to a project. Voluntary
       commitments in proposals become required financial commitments if the proposal is
       funded.
      Voluntary uncommitted cost sharing is defined as over and above that which is
       committed and budgeted for in a sponsored agreement. More specifically, this is either
       additional time or resources provided by the researcher, which were not denoted in the
       proposal, towards completing the project.

Examples of cost sharing include the following:

      Faculty time along with the associated fringe benefits and facilities and administrative
       costs (if allowable by the sponsor)
      Directly related supplies and services
      Equipment
      Unrecovered facilities and administrative costs, if approved by the sponsor
      A nine- month KSU faculty member who is voluntarily working on a research project on
       campus during the summer without compensation
      Time donated by advisory council members
      The value associated with the use of an off-campus meeting hall
      Subrecipient cost-sharing

Commitments to cost sharing and matching should be held to a minimum and should not,
without compelling reason, exceed 5% of total project costs. Regardless of the percentage, the
ability of the University to meet the commitment from acceptable resources must be clear.

As part of the proposal review process, when a Principal Investigator (P.I.) plans to include
either KSU’s resources or external entities’ resources as cost sharing, this information must be
specifically identified on the routing form. It constitutes a formal commitment to the sponsor by
the department chair, dean of the academic unit, director of the center/institute, the Vice
President for Research, or the Provost. In cases where the matching involves external entities, a
letter of commitment from each entity and a detailed budget must be submitted with the
proposal. Any variation from this process must be approved by the Associate Dean for Grants
and Contracts before the proposal can be processed. In those cases where the subcontractors are
providing cost sharing, their budget needs to identify these commitments.

Once the application for the grant, contract, or cooperative agreement is funded by the
sponsoring agency, KSU is required to provide the stated resources listed as cost sharing and the
same fiduciary responsibilities in expending these funds as is done for the funds from the
                                                                                                15
sponsoring agency. The Principal Investigator is responsible for tracking and providing matching
information to the Office of Grants and Contracts.

According to the Office of Management and Budget (OMB) Circular A-110 definitions of cost
sharing and matching, all contributions can be accepted as part of the recipient’s cost sharing
when such contributions meet all of the following criteria:

      Are verifiable from the records of the P.I.
      Are not being included as contributions for any other federally-assisted project or
       program.
      Are necessary and reasonable for proper and efficient accomplishment of project or
       program objectives.
      Are allowable under the applicable cost principles.
      Are not paid by the federal government under another award, except where authorized by
       federal statute to be used for cost sharing or matching.
      Are provided for in the approved budget when required by the federal awarding agency.
Unrecovered indirect costs may be included as part of cost sharing or matching only with the
prior approval of the Federal-awarding agency.

When an application or proposal that contains cost sharing is awarded, KSU is expected to meet
the cost sharing requirement in that application or proposal. If, at the time of award, the
sponsor’s level of support is less than the University’s originally proposed budget, any original
matching commitments offered by the University or external entities on behalf of KSU should be
reconsidered for possible reduction or elimination from the award in consultation with the Office
of Grants and Contracts. If during the life cycle of a project, conditions arise that make it
impossible to satisfy the matching requirements, the Office of Grants and Contracts should be
informed of this by the Principal Investigator. The Office of Grants and Contracts is responsible
for renegotiating any reduction in the level of matching required by the sponsor. The Principal
Investigator is responsible for eliminating any matching shortfall requirements.

To assist the Principal Investigator in capturing the cost sharing information in accordance with
federal requirements, the OGC will provide guidance. In cases where the origin of funds is not
from a federal source, please consult the OGC to determine how the reporting requirements
might vary.

i. Cost Transfers
A cost transfer involves action in which costs are moved from a non-sponsored project account
to a sponsored project or from a sponsored project to any other account. The following
exclusions apply:

      Corrections of processing errors that occur within the Business Services on Payroll
       accounting systems such that when the correction is made, the accounting records are in
       agreement with the documentation that authorized the change.



                                                                                                  16
      Corrections of encumbrances are not considered cost transfers, and any such changes are
       to be processed according to Procurement Office procedures which require written
       notification of corrections to be made to purchasing documents.

Cost transfers receive careful scrutiny by sponsors, especially federal government contracting
officers and auditors and are exceptional activities that should not occur frequently. Cost
transfers to or from grants/contracts should represent corrections and must be made promptly
after the error is discovered. The transfer must be supported by a written explanation of how and
why the error occurred and a certification of the correctness of the new change. An explanation
that merely states that the transfer was made “to correct error” or “to transfer to correct
project” is not sufficient.

Costs may not be shifted between accounts or from one budget period to the next solely to cover
cost overruns. Cost transfers based on funding considerations are prohibited (i.e., cost transfers
cannot be done to expend remaining funds). The intentional ―parking‖ of charges on a restricted
grant/contract pending transfer to another grant/contract account upon its funding is unallowable.
Parking of charges for any reason is considered a misuse of grant funds.

Cost transfers required to correct errors or to achieve proper, consistent, and equitable
distribution of costs to sponsored projects will be allowed, provided adequate justification for the
change is furnished and necessary approvals that certify the accuracy of the charges are received.
A cost transfer made within 30 days after the posting date of the transaction requiring a transfer
will be considered timely. In other exceptional instances, cost transfers may be required after the
30 day period. All cost transfers require a description/justification of why the transfer is needed.
Approval/disapproval of the cost transfer by the Office of Grants and Contracts (OGC) will be
assessed once all documentation and justification has been received. (Per OMB Circular A-21
Section C http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html#c)

Cost transfers of personal service expenses (salary/fringe distribution changes) requests will
require adequate supporting statements that clearly indicate that the costs being moved to a
project are directly related to the project scope and allowable by the project budget and have
been incurred in a timely manner to benefit project activities. In addition, a Time and Effort
report will be required as a back up documentation prior to any personal services reallocations
for federal awards. Justification must always consist of more than simple statement such as ―to
correct an error‖ or ―posted to the project number.‖ While such statements may be correct,
justification must be considered adequate to convince a sponsor or auditor of the accuracy of the
charge to the sponsored project. The designated Project Director or other responsible party must
certify as to the accuracy of the cost transfer. The OGC approves the cost transfer as to accuracy
of the accounting, the proper authorization, and the adequacy of the documentation.

j. Course Release(s) and Redirects
If a grant supports a course release, the Project Director is responsible for responding to requests
from the Office of Grants and Contracts (OGC) via email of the course release(s) schedule to
charge against respective grants. This should be done during the semester in which the course
release is taken. The difference between a full-time faculty member’s salary and a part-time
faculty member’s salary can be significant. This salary difference (excluding any fringe
                                                                                                  17
benefits) can be recovered by the department and used to offset grant or departmental expenses.
The Project Director is responsible for requesting these funds during the semester their course
release is taken.

1. Course Release
    1. The Project Director is responsible for notifying the OGC via email or memorandum of
       the course release(s) schedule to charge against respective grants each semester (Fall and
       Spring) during the semester in which the course release is taken.
    2. Once notified, the OGC will process the course release(s) journal against the respective
       grant to release the funds in the corresponding department.
    3. When Business Services has processed the journal, the OGC will notify, via email, the
       Business Manager with a copy to the Academic Fiscal Affairs Officer in Academic
       Affairs.
    4. The Business Manager is responsible for working with the appropriate person(s) within
       his/her college and the Academic Fiscal Affairs Officer in Academic Affairs to process
       any budget amendments to redirect the funds for his/her college.

In addition, a Time and Effort report will be required as backup documentation for any course
releases and/or redirects charged to federal sponsored awards. [Per OMB A-21 –
http://www.whitehouse.gov/omb/circulars_a021_2004 ]

2. Redirects
Redirects are the portion of salary that is saved in a departmental budget when a grant or contract
pays for all or a portion of a faculty member’s salary.

Redirects can be created by:
   1. Percentage of individual’s salary charged to a grant, releasing that amount in the
       departmental budget
   2. Course release(s) for faculty to work on the grant

*****NOTE: You can only redirect salaries, not fringe benefits*****

The process for releasing redirects is the same as the process for Course Release.

k. Disallowable Expenditures and Overdrafts
Principal Investigators are responsible for tracking expenditures to prevent disallowable
expenditures and overdrafts of sponsored support. In the event that such expenditures occur,
Principal Investigators must expeditiously resolve cost overdrafts and disallowances of
sponsored program funds.

The Office of Grants and Contracts monitors sponsored program accounts to ensure resolution of
overdrafts in conjunction with the administrating department. Disallowed expenditures and
overdrafts will be charged to the Principal Investigator’s department budget account if not
resolved.


                                                                                                18
l. Equipment Management
The Office of Grants and Contracts is responsible for establishing and maintaining accountability
for equipment acquired under grants, contracts, and subcontracts for sponsored programs in
accordance with sponsoring agency directives and University policy. Sponsor definitions of
non-expendable equipment may vary as to the acquisition cost threshold. Most federal sponsors
will utilize the definition contained in OMB Circular A-21, i.e., an acquisition cost of $5000 or
more per unit.

Proposals for awards should specify the type and quantities of equipment required. (As sponsor
agency prior approval policies vary, listing of equipment in an award does not necessarily
provide approval to purchase the equipment.) More specifically, budgeted equipment must be in
compliance with the specific rules and regulations of the sponsoring agency and applicable to the
Office of Management and Budget Circulars governing the expenditure of funds. Be fore
requesting any new equipment, the Principal Investigator must determine that equipment
available to the University will either not meet the project’s property needs or is not available for
use when required.

The Principal Investigator assures that equipment received is as ordered and in good condition.
Any discrepancies or damage should be immediately reported to the Procurement Department.

Responsibility for maintaining physical control of all equipment acquired under an award and
safeguarding it against loss, damage, or unauthorized use rests with the Principal Investigator.
Subcontractors or subgrantees are also responsible for compliance with equipment policies and
requirements and will be so instructed in sub-award documents.

Equipment owned by the federal government or other sponsors is subject to transfer to another
institution when approved and directed by the sponsor agency. A request for transfer of such
property can originate with a researcher transferring to another institution and requiring such
property in the pursuit of continuing research or with the sponsor agency itself. A transfer
originated by a faculty member requires the advanced approval of the appropriate department
head, dean, Associate Dean for Grants and Contracts, and, in some instances, the federal or
sponsor agency. Agency-originated disposition or transfer instructions do not require such
approval. However, if agency-directed or contemplated transfers are likely to impair continuing
research or training projects at the University, such considerations should be promptly brought to
the attention of the agency through the OGC in an attempt to diss uade the agency from making
the transfer. Much of the property acquired on research or training awards becomes University
(State) property upon acquisition or by subsequent vesting of title. Disposition or transfer of
such property is subject to University and State policies.

Any questions relative to these policies or to equipment on a federally-sponsored award should
be directed to the OGC. Please see
https://financialservices.kennesaw.edu/accounting/asset_management_procedures.

m. Export Control
Export Control regulations are federal laws that prohibit the unlicensed export of certain
commodities or information for reasons of national security or protections of trade. U.S. citizens

                                                                                                   19
are criminally liable for violations. Export controls usually arise for one or more of the following
reasons:

      The nature of the export has actual or potential military applications or economic
       protection issues;
      Government concerns about the destination country, organization, or individual, and
      Government concerns about the declared or suspected end use or the end user of the
       export

It is the policy of KSU to abide by export control laws.

Why Are Certain Exports Controlled?

      National Security
      Proliferation of chemical and biological weapons
      Nuclear Nonproliferation
      Missile Technology
      Anti- Terrorism (Cuba, Iran, North Korea, Libya, Sudan, and Syria)
      Crime Control
      High Performance Computer
      Regional Stability
      Short Supply
      U.N. Sanctions

What is an Export?

An export is any oral, written, electronic or visual disclosure, shipment, tra nsfer or transmission
of commodities, technology, information, technical data, assistance or software codes to

      anyone outside the U.S. including a U.S. citizen
      a non-U.S. individual wherever they are (deemed export)
      a foreign embassy or affiliate
Methods of Disclosure Include

      Fax
      Telephone
      Email
      Computer data disclosure
      Face-to-face discussion
      Training sessions
      Tours which involve visual inspections

Who is a Foreign National?

A ―Foreign National‖ is any person who is not a:

                                                                                                   20
      U.S. Citizen or National
      U.S. Lawful Permanent Resident
      Person Granted Asylum
      Person Granted Refugee Status
      Temporary Resident

―Foreign National‖ includes:

      Persons in the U.S. in non- immigrant status (for example, H-1B, H-3, L-1, J-1, F-1
       Practical Training, L-1)
      Persons unlawfully in the U.S.

Agencies with Oversight of Export Control Laws
Most exports do not require government licenses. However, licenses are required for exports that
the U.S. government considers ―license controlled‖ under:
   1. The Department of Comme rce’s Export Administration Regulations (EAR),
      http://www.access.gpo.gov/bis/ear/ear_data.html, which covers [15 CFR 730-774]:
           Dual use items
           Items designed for commercial purpose but which could have military
              applications (computers, civilian aircraft, pathogens)
           Both the goods and the technology
           Deemed Exports

       The Commerce Control List (Short Version)

              Nuclear Materials, Facilities & Equipment (and Miscellaneous Items)
              Materials, Chemicals, Microorganisms, and Toxins
              Materials Processing
              Electronics Design, Development, and Production
              Computers
              Telecommunications and Information Security
              Sensors and Laser
              Navigation and Avionics
              Marine
              Propulsion Systems, Space Vehicles, and Related Equipment

   2. The Department of State’s International Traffic In Arms Regulations (ITAR),
      http://pmddtc.state.gov/regulations_laws/itar.html (also known as the U.S. Munitions
      List) covers defense-related items and services [22 CFR 120-130]:
           Covers military items or defense articles
           Regulates goods and technology designed to kill or defend against death in a
              military setting
           Includes space-related technology because of application to missile technology

                                                                                              21
              Includes technical data related to defense articles and services

   3. The Treasury Department’s Office of Foreign Assets Control (OFAC) administers
      and enforces economic and trade sanctions that have been imposed against specific
      countries based on reasons of foreign policy, national security, or international
      agreements. Full descriptions of all countries currently subject to boycott programs are
      available at http://www.treas.gov/offices/enforcement/ofac/.
           Regulates the transfer of items/services of value to embargoed nations
           Imposes trade sanctions, and trade and travel embargoes aimed at controlling
              terrorism, drug trafficking, and other illicit activities
           Prohibits payments/providing value to nationals of sanctioned countries and some
              specified entities/individuals
           May prohibit travel and other activities with embargoed countries and individuals
              even when exclusions to EAR/ITAR apply.

       OFAC Sanctions:

              Balkans
              Burma
              Cote d’Ivoire
              Cuba
              Iran
              Iraq
              Liberia
              Libya
              North Korea
              Sudan
              Syria
              Zimbabwe

Export Control License

      An export license may be required before a controlled item or material may be exported
      There is usually a lengthy processing time period
      Denial possible
      Approval may contain restrictive conditions

A slideshow on export controls and embargoes is located at
http://www.kennesaw.edu/ogc/NewAgencyRegs.html

n. Facilities and Administrative (Indirect) Costs
Unless prohibited by the funding agency, all requests for extramural funding must include
facilities and administrative costs. Modified total direct costs include all salaries and wages,
fringe benefits, materials, supplies, travel, and the first $25,000 of each subgrant/subcontract.


                                                                                                    22
Capital expenditures and the portion of each subgrant/subcontract in excess of $25,000 are
excluded.

Facilities and administrative costs reimburse the University for laboratory and office space;
utilities; administrative services (e.g., purchasing, accounting, research administration,
personnel, security); custodial services; and building, grounds, and street maintenance. In other
words, they include all those things essential to support sponsored research which cannot be
broken down and directly charged to a specific grant or contract.
There are organizations which, by regulation, limit facilities and administrative cost recovery. If
a proposal is being submitted to such an agency, a copy of their policy must be submitted to the
OGC with the proposal, or a waiver must be provided.

The University has separate facilities and administrative costs rates for research performed on
and off campus. Based on the terms of KSU’s federally- negotiated facilities and administrative
costs agreement, the off-campus facilities and administrative cost rate applies to all activities
performed in facilities not owned by the institution and to which rent is directly allocated to the
project. Information on facilities and administrative costs is located at
http://www.kennesaw.edu/ogc/postaward_toolkit/postaward_handbook/KSU_Indirect_Cost_Rat
e_Letter.pdf

Senate Bill 73, enacted in the 2003 state of Georgia legislative session, allows for indirect cost
recovery year-end balances to be exempt from state law concerning lapsable funds. In order to
properly account for these funds and allow remaining balances to carry forward.

 Upon the request of the Provost and the Deans, the transfer of earned indirect costs has also
changed. Project Directors no longer need to request disbursement of their indirect cost funding.
Instead, the OGC automatically transfers any earned indirect cost funding to the respective
Dean’s indirect account on a quarterly basis. Business Managers receive email notification each
quarter indicating that the indirects journal has been posted. Business Managers may, upon
approval of the Dean, transfer funds from the Dean’s indirect account to an indirect account
established under a department within the college; however, funds cannot be transferred to a
regular state departmental account.

o. Fixed-Price Contracts
Most awards are cost-reimbursable. However, under some circumstances, a fixed-price contract
may be negotiated.
In those cases where an agreement is a fixed-price contract (generally research institutes and
centers), provisions must be made by the Principal Investigator (P.I.) and/or department or center
having primary responsibility for the project to cover any overdrafts or excess funds.

Upon completion of the project and confirmation from the sponsor that the terms of the contract
have been satisfactorily met, the facilities and administrative costs budget will be adjusted to
charge the contract the full F&A budget, subject to availability of the excess funds. Any
remainder after covering the adjusted F&A costs will belong to the P.I. and/or department or
center having primary responsibility for the project.
                                                                                                     23
p. Grant Residual Funds
A residual balance is defined as unobligated funds remaining in a sponsored project/grant
account at termination and closeout. This usually occurs with a fixed-price contract.

If allowable by the funding agency/sponsor under the specific grant/contract terms,
contracts/grants/agreements that carry a balance after the period of perfor mance will be
permitted to do one of the following:

   1. carry forward that balance through the next fiscal year following the period of
      performance and then transfer the funds to the PI’s department account or
   2. transfer the balance directly to the PI’s department account.


Balances of $100 or less will be automatically transferred to the PI’s department account.

In addition, any residual funds must be used for a purpose which is related to the contract or to
further enhance programs with the PI’s college. Resid ual funds can also be used to support the
professional development of the project director or other faculty members in his/her college.
State rules and regulations will apply to any residual funds.

Upon project completion and before the residual balance can be spent, the following information
must be submitted and confirmed in writing to the Office of Grants and Contracts (OGC) by the
project director.

   1.   All work has been completed.
   2.   No outstanding items remain open or in question with the sponsor.
   3.   All reports (technical and financial) have been received and accepted by the sponsor.
   4.   All costs have been applied to the University’s sponsored project account.
   5.   All payments for the project have been received from the sponsor.
   6.   All state funds used in the conduct of the project have been recovered.


If the residual balance is extended in the current grant account by OGC for one fiscal period,
OGC will notify the project director, business affairs manager, department chair and dean via
memorandum or email of the remaining grant/contract balance and extension period. If the
residual funds are not spent by the end of the extension period, the funds will be transferred to
the departmental budget for on fiscal period. Funds transferred to the department will laps at the
end of one fiscal period.

If the residual balance is transferred to the department budget immediately following grant
closeout, funds will laps at the end of the fiscal year.




                                                                                                    24
q. Hiring Personnel
If your grant or contract includes new personnel, please contact your representative in Human
Resources for assistance.

r. Leave Benefits
Personnel paid from a sponsored program account receive the same leave benefits as personnel
paid from other University funds. Staff and fiscal year appointees are encouraged to utilize
accrued vacation before the program’s termination date. If the contract or grant does not have
sufficient funds to pay the accrued vacation, it is the responsibility of the employing department
to provide the necessary funding. The Principal Investiga tor must ensure that these employees
accurately report their vacation time prior to the project’s expiration.

s. Lecture/Performance Agreement
Lecture/Performance agreements are used when a guest lecturer speaks during a class, workshop,
seminar, etc. All requests to hire a lecturer should be made using the Lecturer Performance
Agreement form. This form is available on Procurement’s website at

https://financialservices.kennesaw.edu/files/Forms6/procurement/procure_form_lecture_perform
ance_agreement.pdf. Requests to hire a lecturer must be fully approved prior to work beginning.
An active Kennesaw State Unive rsity employee cannot be paid as a lecture r.

[Per OMB Circular A-21 Section J (General provisions for selected items of cost) #37
http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html]

t. Membe rships, Subscriptions, and Professional Activity Costs
Institutional memberships (professional organizations), subscriptions (technical periodicals), and
professional activities are normally treated as an F&A cost. Costs of membership in any civic
organization, country club, social, or dining club are unallowable. An individual membership or
subscription to a professional group or periodical may be allowed as a direct charge if the
following can be demonstrated.

   1. The membership created a cost-savings to attend a conference at which research results
      specific to a project will be presented, or membership is mandatory in order to present a
      paper specific to the project or
   2. The sole purpose of the membership is to purchase a periodical at a reduced rate. The
      periodical is not available through the institution’s library services, and the periodical is
      necessary for the sponsored project.

u. No-Cost Extension
Should you be unable to complete your project by the end date, you may request a no-cost
extension. Most federal agencies allow the Office of Grants and Contracts to make up to a one-
year, no-cost extension. For other agencies, prior approval is required from the funder.

No-cost extensions should be requested through the OGC at least 45 days prior to the project end
date using the Administrative Action Request Form in Appendix D. To determine if agency
approval is required, see the matrix in Appendix C and review your grant terms and conditions.
                                                                                               25
v. Overtime for Employees
Some personnel must be paid time-and-a-half for hours worked in excess of forty (40) hours per
week. The Office of Human Resource Services should be contacted before hiring a person
already on the payroll.

w. Pre-Award Costs
Approval may be granted for expenditure of funds up to 90 days prior to the expected start date
of a new award. Advance funding must be necessary for the effective and economical conduct
of the project. Pre-award costs will not be approved unless a department chair or dean
guarantees to reimburse KSU in the event the grant is not received.

Not all agencies allow pre-award cost. Please see the matrix in Appendix C. If your funder
allows pre-award cost, please complete the Administrative Action Request Form, secure the
signatures, and send it to the OGC.

x. Procurement Services
If your grant includes funds for equipment, please contact Procurement Services
https://financialservices.kennesaw.edu/procurement/. This office should also be consulted if you
have included unnamed consultants in your grant budget.

y. Procurement Cards
The Project Director is responsible for verifying that all procurement card expenses charged to
his or her grant are in compliance with the award/contract. Additionally the Project Director is
responsible for following KSU Business Services, DOAS, and BOR procurement card policies.
no matter who holds the procurement card. If invalid or unauthorized purchases are charged to a
grant using a procurement card, the College/Department budget will absorb the expense. If the
expenses cannot be absorbed by the College/Department, i.e., expenses cannot be paid with state
funds, all charges will become the responsibility of the Project Director. Business Services will
set up a receivables account in the Project Directors name to collect any funds that cannot be
absorbed by the College/Department.

Project Directors are responsible for verifying that all charges booked to their grants by
procurement card, no matter who holds the procurement card, are allowable, allocable and
reasonable as Per OMB Circular A-21 Section C.
http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html#c

Please refer to the links below for consequences of procurement card violations. Cardholders
with repeat violations of this policy will be subject to revocation of their P-Card privileges.

The link to Business Services procurement card policies is below:

http://doas.ga.gov/StateLocal/SPD/Docs_SPD_Cards/PCard_Policy.pdf

The link to DOAS procurement card Policies is below:


                                                                                                  26
http://doas.ga.gov/StateLocal/SPD/Pages/Home.aspx

The link to BOR policies is below:

http://www.usg.edu/sites/404

During the last 60 days of the award, no procurement card charges should be made to the
grant. Any procurement card expenses that are not on KSU’s ledgers b y the grant end date will
become the responsibility of the Project Director’s department. Project Directors should keep
copies of any procurement card statements and receipts that are charged to their grants and send
a copy to the OGC for the grant file.



   1. Colleges with Business Managers should submit their monthly reconciliation to their
      respective Business Manager to ensure proper allocation of expenses to a grant/contract.
      Failure to submit this form with monthly reconciliation will result in the expense being
      charged to your department account.
   2. Areas without Business Managers should submit their monthly reconciliation to Business
      Services to ensure proper allocation of expenses to a grant/contract. Failure to submit
      this form with monthly reconciliation will result in the expense being charged to your
      department account.
   3. Cardholders in Colleges with Business Mangers are responsible for providing an
      additional copy of all grant/contract P-Card purchases for each grant expense to their
      Business Manager. The Business Manager will forward a complete copy along with the
      Payable Allocation Report (from Works) to the Office of Grants and Contracts (OGC) for
      grant records/audit compliance.
   4. Cardholders in areas without Business Managers are responsible for providing a copy of
      all grant/contract allocated P-Card purchases for each grant expense and Payable
      Allocation Report (from Works) to the OGC for grant records/audit compliance.
      Information should be received in the OGC by the last working day of the month. Failure
      to submit a copy to the OGC could result in a minor P-card violation.
   5. Cardholders with repeat violations of this policy will be subject to revocation of their P-
      Card privileges. [Per OMB Circular A-21 Section C
      http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html#c]


z. Professional Service Costs
Costs of professional and consultant services rendered by persons who are members of a
particular profession or possess a special skill, and who are not officers or employees of the
institution are allowable.

aa. Program Income
Program income is the gross revenue earned from activities for which the direct costs have been
charged to a grant (or subgrant) or counted as a direct cost toward meeting a cost sharing or
matching requirement of a grant.
                                                                                                 27
Examples of program income are:

      Fees for services such as laboratory drug testing or conference fees
      Proceeds from sale of equipment or supplies purchased or constructed with grant funds if
       title does not vest in the grantee
      Usage or rental fees charged for use of facilities or equipment such as computer use
       charges
      Funds generated by the sale of commodities such as sale of tissue cultures, cell lines, or
       research animals
      Third party patient reimbursements for hospitals or other medical services where such
       reimbursement occurs because of the grant supported activity
      Patent or copyright royalties

The Office of Grants and Contracts should be contacted at the time it is recognized program
income will be generated. They will assist in establishing the proper method of accounting for
the income. Since program income has the same accountability requirements as federal grant
funds, the OGC will select a mechanism which will account for program income in accordance
with federal requirements.
Program income, in accordance with specific agency requirements, is reported to the sponsoring
agency on financial reports which are prepared periodically.

bb. Recommended Purchasing Deadlines for Grants
All grant expenditures must be posted on KSU’s financial ledgers prior to the grant end date.

   1. KSU P-Card Deadlines—60 days before the end date of the grant

   2. KSU AGS/Misc. Deadline—30 days before the end date of the grant

   3. KSU Travel Expense Statement Deadline—30 days before the end date of the grant

   4. Grant-Specific Deadline(s)—You must reference the individual grant/contract for grant-
      specific deadlines set by funding agencies (i.e., narrative reporting, etc.). All fiscal
      reporting is done by the Office of Grants and Contracts (OGC). Please contact the OGC
      if you have any questions or concerns with the above recommended deadlines.

cc. Salaries and Wages
Salaries and wages are allowable as a direct cost to the extent that they are reasonable and
conform to established University salary and wage policy. All personnel involved in a sponsored
project effort, whether faculty, professional staff, clerical staff, or students (research assistants),
must be paid in accordance with University and state guidelines. The salary and wage categories
and job or position classifications on sponsored projects must be congruent with those
established for all other employees of the University. Salary rates and increments are, therefore,
subject to the regulations applied to all other University employees of the same classification.
Exceptions result in audit disallowances.

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Salary and wage rates contained in a proposal, including projected increases, are budgetary
figures. All personnel commitments are handled in conformity with established University salary
and wage policies. Budgetary data contained in a proposal does not in any way supersede such
policies.

All University personnel must be paid through the University payroll system. In addition, all
students who are enrolled at the University and are being paid for services rendered must be paid
through the University payroll system.

dd. Summe r and Maymester Payroll
The Project Director is responsible for ensuring his/her department chair submits to Academic
Affairs the faculty names, amounts, and grant account for those who are budgeted to be paid
Maymester/Summer payroll from his/her grant.

Maymester payroll is charged to the current fiscal year, and Summer payroll is charged to the
next fiscal year. Maymester payroll is paid for work completed during the month of May, not
June.

If work is done during the summer months (June and July), faculty should be paid through
Summer payroll which posts in the next fiscal year. Thus, the grant end date should carry into
the next fiscal year in order to support the processing of Summer payroll through the award.

In addition, a Time and Effort report is required as backup documentation for any
Maymester/Summer payroll charged to federal sponsored awards. [Per OMB A-21 –
http://www.whitehouse.gov/omb/circulars_a021_2004 ]


For specific KSU submission deadlines for faculty payroll, please contact the Office of
Academic Affairs. For KSU Maymester/Summer payroll check dates, please contact the Office
of Payroll.

ee. NSF’s Two-Ninths Rule:
During the summer months or other periods not included in the period for which the base salary
is paid, salary is to be paid at a monthly rate not in excess of the base salary divided by the
number of months in the period for which the base salary is paid. NSF policy on funding of
summer salaries (known as NSF’s two-ninths rule) remains unchanged: proposal budgets
submitted should not request, and NSF-approved budgets will not include, funding for an
individual investigator which exceeds two- ninths of the academic year salary. This limit includes
summer salary received from all NSF-funded grants.

ff. Space Rental
In some cases a University department, school, or center may require rental space to house a
sponsored project. If off-campus space is required, the Associate Dean for Grants and Contracts
must be contacted early in the proposal stage to assure that University and State regulations are

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followed. If rent is charged to the funding agency, then the off-campus indirect cost rate should
be used.

gg. Stipends
Stipends are paid to individuals under training grants which are intended to provide financial
assistance during the period of the grant. Payments are made for attendance at workshops,
training sessions, and meetings, etc. No services are rendered to KSU by the individual. An
individual can be paid a flat rate amount or a flat rate amount plus additional travel expenses.
[Per OMB Circular A-21 Section C
http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html#c] Please submit an ASG for
payment. For specific questions regarding the AGS, please contact Accounts Payable in the
Office of Business Services.

hh. Subcontract and Subgrant Effort
Some sponsored program projects require the University to collaborate with other institutions or
contractors. Such effort must be defined in the proposal and approved by the sponsor agency in
advance. Subcontract or subgrant documents must also be approved by the sponsor agency prior
to finalization of any such agreement. During any programmatic discussions with potential
subcontractors or subgrantees, financial commitments or arrangements must be coordinated with
and approved by the Office of Grants and Contracts. As audits are generally required for all
subcontracts, the University’s proposal must provide for the costs of such audits or contain
assurances that the audit will be accomplished. Other universities are also subject to federal
audit requirements and can generally provide needed audit information without the need for a
separate subcontract audit. Contact the OGC for additional information and guidance on this
requirement.
Except for the estimated cost for auditing a subcontract, all subcontract costs are a composite
direct cost as far as the University is concerned and should always be shown in the subcontract
cost line of the proposal. Although it is expected that subcontract costs will be broken out and
supported in the subcontractor’s proposal to the University, subcontract costs should never be
intermingled with KSU cost elements. Each subcontractor that includes facilities and
administrative costs as part of their overall budget needs to provide a copy of their most recent
federally- negotiated facilities and administrative costs rate agreement.

Where is it known in advance that specific organizational entities are essential to and will
collaborate on a sponsored project, it is customary that estimated costs to be included in the KSU
proposal be corroborated by an official proposal from that organization prior to submission of the
KSU proposal.

ii. Supplies
Generally, grant and contract funds may be used to purchase supplies delivered on or after the
beginning date of the project. Purchases made during the latter part of a project are subject to
particular audit scrutiny and, therefore, must be sustaining from the view points of relevance and
usefulness to the project. Failure to adhere to these stipulations can result in audit exceptions
and costs disallowance.

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If supplies are not received prior to the termination of an award or contract, it will normally be
necessary to utilize and charge the supplies to the continuation award or to another active project
which requires and can effectively utilize the supplies. Where the usage and charges for such
supplies cannot be legitimately absorbed by another active project or departmental budget,
prompt action should be taken to cancel outstanding orders and avoid the incurrence of a
financial obligation not covered by an authorized budget.

jj. Time and Effort Reporting

Office of Management and Budget Circular A-21 requires certification for payroll distribution
purposes for all payroll charges to federal contracts and grants of professorial, professional, or
support staff. These time and effort reports account for 100% of each individual’s university
responsibilities even if he or she is part time. Charges for work performed on sponsored
agreements by faculty members during the academic year will be based on the individual faculty
member’s regular compensation for the continuous period which, under the policy of the
institution concerned, constitutes the basis of his/her salary. Charges for work performed on
sponsored agreements during all or any portion of such period are allowable at the base salary
rate. In no event will charges to sponsored agreements, irrespective of the basis of computation,
exceed the proportionate share of the base salary for that period. This principle applies to all
members of the faculty at KSU.

OMB Circular A-21 requires that the payroll distribution system (time and effort reporting) will
(i) be incorporated into the official records of the institution, (ii) reasonably reflect the activity
for which the employee is compensated by the institution, and (iii) encompass both sponsored
and all other activities on an integrated basis. The Office of Grants and Contracts is responsible
for distributing, collecting, reviewing, and maintaining the official file of time and effort reports.
The percentages reflected on the time and effort reports are based upon the amounts charged to
contract and grant accounts in the University payroll system, which may not reflect actual effort
expended. The percentages must be changed to reflect the actual activity expended before they
are certified.

A time and effort report is created each semester for all faculty, staff, or temporary salary
charged to federal sponsored agreements. The distribution of salaries and wages is based on
payrolls documented in accordance with the generally accepted practices of colleges and
universities. Certification of the effort requires that the person signing the time and effort report,
whether it is the principal investigator, department chair, or dean, have first-hand knowledge of
all the employee’s activities during the reporting period. The information certified by the
departments for pay periods reflects the actual activity of each employee as well as it can be
measured. A certified time and effort form is a certified legal document.

Mandatory committed effort is effort activity required by the sponsored agency as a condition of
making the award and committed by the principal investigator.

Voluntary committed effort is effort not required by the sponsoring agency but volunteer and
committed by the principal investigator.

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Kennesaw State University currently uses the After-the-fact Activity Reporting for Professorial,
Professional, and Non-Professional employees. [Per OMB A-21-
http://www.whitehouse.gov/omb/circulars/a021/a021.html]

After-the-fact Activity Records: Under this system the distribution of salaries and wages by the
institution will be supported by activity reports as prescribed below.

           a. Activity records will reflect the distribution of activity expended by employees
              covered by the system.
           b. These reports will reflect an after-the-fact reporting of the percentage distribution
              of activity of employees. Charges may be made initially on the basis of estimates
              made before the services are performed, provided that such charges are promptly
              adjusted if significant differences are indicated by activity records.
           c. Reports will reasonably reflect the activities for which employees are
              compensated by the institution. To confirm that the distribution of activity
              represents a reasonable estimate of the work performed by the employee during
              the period, the reports will be signed by the employee, principal investigator, or
              responsible official(s) using suitable means of verification that the work was
              performed.
           d. Where the institution uses time cards or other forms of after-the- fact payroll
              documents as original documentation for payroll and payroll charges, such
              documents shall qualify as records for this purpose, provided that they meet the
              requirements in subsections (a) through (c).

The form for recording time and effort can be found on the Office of Grants and Contracts
(OGC) website at http://www.kennesaw.edu/ogc/PostAward/Forms_Post-Award.html. These
reports should be turned into OGC at the end of each month, no later than 15 days after the end
of the month. Each report must be signed and dated b y the employee who performed the work
and by the project director (or department chair if the time and effort is for the project director).
The form cannot be signed (certified) before the end of the reporting period (i.e., month).
Employees involved in certifying their own or someone else’s effort must understand that severe
penalties and funding disallowance(s) could result from inaccurate or untimely effort reporting.
Only individuals doing the work or an official (that is not subordinate of the individ ual) who has
direct knowledge of that work is authorized to certify these reports. It is the responsibility of the
project director to return the completed personnel activity form to OGC. Any incomplete forms
will be returned to the project director for co mpletion.

Retroactive changes to time and effort reports must give full consideration to previous
certifications on file and must be documented and explained in a manner which unequivocally
substantiates the propriety of the adjustment.

Changes of distribution of workload may not normally be made for any prior pay period. In the
following exceptional situations, however, retroactive changes may be warranted:

      When necessary to correct clerical and data entry errors.

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      When subsequent information is received indicating an incorrect original entry.
      When required to properly change non-federal funds for costs incurred in connection with
       an award that fails to materialize.
      When closely related work is supported by more than one funding source, costs may be
       transferred from the originally charged fund to another fund, provided the cost is a proper
       and allowable charge to the receiving account and the interrelationship between the
       accounts is fully explained in the request. If an over-expenditure is being transferred to
       another project, especially strong supporting evidence is required for approval.

Unacceptable changes include the following:

      When the change is for the purpose of utilizing unexpended funds of a federal award.
      When the change is for the purpose of circumventing award restrictions.
      When the change is for the purpose of avoiding a cost overrun by charging another,
       unrelated federal agreement.
      When explanation merely states ―to correct error‖, ―to transfer correct project‖, or other
       similar insufficient reasons.
      When a change unrelated to sponsored agreements applies to a closed fiscal year.

kk. Time-Limited Appointme nts
Normally, positions under contracts and grants are time-limited and for a stated definite term.
Otherwise, an employing unit has a continuing obligation to the person after the end of the
funding period. During the recruitment period, the Principal Investigator will be advised by staff
in the Office of the Provost and/or the Office of Human Resources about how to describe the
position to interviewees.

ll. Travel
Travel expenses are allowable if authorized and in direct support of the project. All travel
reimbursements, both to University and non-University employees, are subject to state and
University travel policies except in those few instances where more restrictive policies and
limitations may be imposed by a specific award. Federal travel regulations will apply when
required by federal contracts.

mm. Utility Services
Utility costs, such as heat, light, water, air conditioning, and local telephone service are recouped
through the indirect cost rate and are not considered as direct costs. In unusual circumstances,
where inordinate amounts of such services are required for a project, it may be appropriate to
direct cost these items. The Office of Grants and Contracts can assist departments in such
circumstances.

nn. When Administrative and Clerical Salaries and Staff Benefits Can Be Charged as
    Direct Costs
Salaries and fringe benefits of administrative and clerical staff may be charged as direct costs in
instances where sponsored projects require the services of administrative and clerical staff
beyond the normal level provided by departmental administrators paid from a department
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account. The total cost of these services may be budgeted, charged, a nd reported as a direct cost
to a sponsored project when all of the following conditions apply.

   1. The specific type and nature of the services are not provided by the departmental
      administration account.
   2. The services are required by the project’s scope.
   3. The cost can be accurately identified to the project.
   4. The approved project budget narrative clearly describes the need for the service.
For example, charging administrative and clerical salaries and fringe benefits as a direct charge
to a sponsored project may be permissible for projects that require

      Extensive data accumulation, statistical analysis and entry, database management,
       surveying, tabulation, cataloging, and literature review,
      The preparation and production of manuals and large reports or books. This does not
       include routine progress and technical reports,
      Extensive travel and meeting arrangements for a large number of participants, such as
       conferences and seminars,
      The management of a project at locations that are geographically inaccessible to nor mal
       departmental administrative services, such as research field sites remote from campus,
      Special research security services at a level not normally provided by campus security,
      Large, complex programs (such as general clinical research centers, primate centers,
       environmental research centers, engineering research centers, and other federally
       sponsored projects) that entail assembling and managing teams of investigators from a
       number of institutions or units. National Institutes of Health R01 grants do not qualify as
       complex programs.
These examples are not an exhaustive list, nor do they imply that direct charging of
administrative or clerical salaries would always be appropriate for the situations illustrated in the
examples. Individual projects cannot be grouped together to meet any of the criteria listed
above.
The Principal Investigator or Project Director must support and justify in the proposal all direct
costs to be charged to a sponsored award.

oo. Closeout of Agreements
In order to comply with federal regulations addressing project closeout (Federal Circulars A-21
and A-110), a formal project closeout process consists of the following steps:

      The Office of Grants and Contracts, in order to lay out the actions to be taken, will
       contact the Principal Investigator 60 days prior to the end of the project.
      The Principal Investigator is responsible for initiating any requests for extensions by the
       funding agency via the Office of Grants and Contracts. Prior to requesting the extension,
       an assessment of the budget status and the timeframe in which to complete the
       expenditures should be addressed with the Office of Grants and Contracts. This will help


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       assure that all fiscal matters, including matching, are appropriately considered in the
       request for extension. See Administrative Action Request Form in Appendix D.
    Accounts will be frozen after the project termination date so that transactions after that
       time can be charged to the account after review and approval of the Office of Grants and
       Contracts.
    The Principal Investigator will work with the Grants and Contracts to ensure that all
       transactions are completed and charged to the accounts prior to the prescribed sponsor
       deadline. At most this could be a 90-day period following the end of the grant.
The project closeout checklist is located in Appendix A.

                                  X. Audit Matters and Reports

a. General
All contract and grant funds awarded to the University are subject to audit. This audit can be
performed by any one or combination of the following people:

      University Internal Auditor
      Office of the State Auditor
      Federal Auditors
      Public Auditors

b. Focal Point for Audit Matters
The Office of Grants and Contracts is responsible for coordinating all audit matters relative to
sponsored research of the University. All federal, state, and public firm auditors must make their
initial contact with the OGC when conducting audits relative to contract and grant matters.
Subsequent contacts by auditors with other University departments will be preceded by advance
notice from the OGC. The purpose of the advance contact is to identify the auditors, outline the
general purpose of the visit, and facilitate the audit. If there are any questions concerning the
official status of an auditor, the OGC must be contacted.

c. Grants Accounting Administration Representation
Depending upon the nature of the audit or subject matter, the OGC may elect to be represented in
audit discussions at the departmental level. Should departmental personnel require guidance at
any time, the OGC must be contacted without hesitation. The OGC participates in and
coordinates audit exit briefing as deemed necessary by the significance and nature of the audit
findings and recommendations.

d. Right of Access
Under the legal terms of grants and contracts awards, auditors have the right of access to all
official University records associated with an award. The University is obligated to make such
records readily available for examination.

e. Exit Conference
At the conclusion of an audit and prior to the issuance of the formal report, auditors normally
conduct an exit conference. The purpose of this meeting is to review audit findings and tentative
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conclusions, exceptions, and recommendations. At this meeting, the University has an
opportunity to comment on the audit findings and to provide additional information where
appropriate.

f. Audit Response
The OGC is responsible for coordinating the University’s response to those audits concerned
with contracts and grants. This responsibility in no way relieves the Principal Investigator or
department concerned from providing necessary input in a timely manner or form resolving
financial liability, which may ultimately be assessed as a result of audit exceptions.

The University’s response must be coordinated through established channels. There are no
circumstances under which a department or individual must initiate a direct response to an audit.

g. Cost Disallowance
Established University policy is that financial responsibility for audit disallowances rests with
the Principal Investigator, department, and college having primary responsibility for the project
on which costs are questioned. Disallowances cannot be charged to any federal or state-funded
accounts. Personal liability may be considered and assessed when an audit disallowance
stemmed from gross negligence or malfeasance on the part of an employee or staff member.




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