Contents

Budget & Expenditures

Please see the resource page for more information on Carryforward

Automatic

If your Sponsor allows unspent funds from one budget period to another within the same competitive segment, typically, Boston University will allow you to keep the same Internal Order number for the life of the competitive segment and spending should continue without restriction.

If carryforward is allowed between segments without Sponsor approval, Post Award Financial Operations will reduce the budget for segment 1 and increase the budget for segment 2 when the Sponsor approves the financial report for segment 1.

Sponsored Approval Required

If your Sponsor does not allow automatic carryforward, you will typically get a new Internal Order number each budget year. After the annual close out is completed, the Principal Investigator initiates the request for carryforward working with their Sponsored Programs Research Administrator.

Once carryforward is approved by the Sponsor, Sponsored Programs will add the funds to the next budget year. Post Award Financial Operations has already reduced the prior year budget.

Boston University’s Facilities & Administrative (F&A) Fringe Benefit and Graduate Student Health Plan rates are negotiated with the US Department of Health & Human Services.

Rates found here should be reflected on all future grant and contract proposals for the dates specified.

The F&A rates are typically applied on a modified total direct cost (MTDCModified Total Direct Cost) basis. MTDC is defined as total direct costs less the following expenses:

  • Room and/or board allowance
  • Patient services
  • All movable capital equipment costing $5,000 or more
  • Subcontract costs exceeding $25,000 on each subcontract
  • Student Aid
  • External rent
  • Alteration and renovation costs

In accordance with federal regulations governing the calculation of fringe benefit rates, Boston University has removed the costs associated with tuition remission for family members of employees from the federal fringe benefit costs pool. Although the federal government has disallowed tuition remission for family members as a component of the fringe benefit rate, Boston University’s fringe benefit policy for faculty and staff, including family members, remains unchanged.

In order to continue this benefit for our employees and their family members, it is necessary to establish separate fringe benefit rates for federal awards (including awards with federal pass-through funding) and non-federal awards. The non-federal fringe benefit rates include the costs of tuition remission for family members of employees.

The Graduate Student Health Plan rate will be applied to the amounts paid to graduate students (GL accounts 500410, 500420) supported by continuing awards and new sponsored program awards, as well as those supported by endowment, gifts, or discretionary accounts.

As a best practice, Departments and Faculty should be reviewing their reports on a regular basis utilizing the Business Warehouse reports.

Some things to look for:

  • Do you recognize all of the individuals listed as being paid?
  • Are the salary charges what you expect them to be?
  • Are your subcontractors invoicing?
  • Do you have an appropriate burn rate? i.e. spending too fast or too slow?
  • Ensure budget amount is what you expected?
  • Are there any expenses that you do not recognize?
  • Do you have a NIH annual progress report due within the next quarter? Do you have more than 25% of the current year budget unspent?

 
Effective July 1, 2011, Boston University has revised its requirements related to the prior review and approval of sponsored research expense transactions. Sponsored research activity consists of expenses charged to Grants in SAPBoston University’s financial system that begin with 50 (Federal) or 55 (Non-Federal). The following table summarizes those transactions that require prior approval by Research Accounting. For convenience, this table also includes the approval thresholds that were in place in the legacy financial system prior to the SAP implementation on July 1, 2011.

Transaction Type Current
Payroll Assignments
(Formerly known as Turnarounds)		 No Approval Required
Salary Adjustments* Approval Required
Internal Service Requisitions – Original Charges
(i.e. Service Center billings)		 No Approval Required
Journal Entry – Cost Transfers
(Transaction Code “ZK” or “ZV”) Journal Entry – Original Charges not via ISR (Transaction Code ZJ)		 Approval Required * ZJ entries for original charges processed by Service Centers now route to PAFOPost Award Financial Operations PAFO assists faculty and ... beginning January 2015
Subcontractor Invoices Approval Required
Travel Advances / Expense Reports Approval Required Over $1,000 if reimbursement is not via the travel card implemented February 18, 2015
Shopping Carts and All Other
Non-Salary Transactions		 No Approval Required (Except Capital Equipment)

Note that the primary changes relate to the review and approval of non-cost transfer related transactions (except as noted above). Formerly, Research Accounting provided prior approval of all salary and wages charged to sponsored awards as well as all non-salary transactions with a cumulative total in excess of $1,000. This approval was necessary primarily due to limitations of legacy financial system validations. The system was unable to compare transaction dates with the period of performance of individual sponsored awards. In addition, the system did not contain a budget review mechanism. SAP provides functionality to validate dates and budgets and as such, it is no longer necessary for Research Accounting to provide advance review and approval for routine, low-risk transactions.

*For the purposes of this policy, “Salary Adjustments” include any retroactive revisions to salary and wage distributions and are requested in the “Personnel Actions” tab in the SAP Business Warehouse.

Sponsored Research Cost Transfers
Departments are allowed to transfer costs between $10K and $25K from a University cost center to a Sponsored Research account if the required bid documentation or sole source justification is attached. In Instances where bid documentation or sole source justification is not available, the transfer will not be approved. See the Policy on Competition and Supplier Selection for Products and Services

Principal Investigators (PIs) and Department Administrators must ensure charges to sponsored projects are accurate and in accordance with direct charging practices described in 2 CFR 200 Uniform Guidance and university policy. On a regular basis, the Department Administrator should run financial reports for each sponsored project using Boston University’s Grants Management (Distributed) Reports, which are found in the “Reporting” tab of the BUWorks Central Portal. The administrator must work with the PIPrincipal Investigator View Boston University's policy on... to review these reports to check/validate the financial status of each project and to identify legitimate errors.

Research Accounting will periodically review post audit samples to identify potential instances of noncompliance. If unallowable expenses are identified, the department will be promptly notified and asked to move the charges to a non-sponsored account.
Please review sponsor award terms and conditions prior to expense processing to ensure compliance with all sponsor regulations. If you are unsure whether an expense item is allowable on a particular award, please contact Research Accounting at 617-353-4555. If you have other questions or concerns, please contact the Assistant Vice President for Post Award Financial Operations at 617-358-6361.

Re-budgeting may be required throughout the life of the project. In some cases, re-budgeting will have to be approved by the Sponsor. Listed below are common examples of when a Sponsor requires such a re-budget. In some cases, departments want to re-budget their award in order to align budget with expenditures. This is not a requirement by the Sponsor, however, it is something that departments can work with their Sponsored Programs Research Administrator to achieve.
 

Change of Scope

If the Principal Investigator changes the scope of the award, a re-budget to achieve the new goal may be necessary. The change in scope and the budget request must be submitted through the Sponsored Programs Research Administrator for Sponsor approval.

Most common changes of scopes:

  • PI is leaving the project for 90 days or more
  • PI is changing their effortThe term Effort is used for persons charged to Sponsored Res... More by greater than 25%
  • A subcontract is being added that was not in the initial budget

Equipment

If your award restricts the use of equipment or is specific to the piece of equipment you can purchase and you need to make a change, this requires Sponsor approval and must be submitted through the Sponsored Programs Research Administrator.

If the equipment is over the capitalization threshold and was not originally budgeted, regardless of whether or not Sponsor has to approve, some schools require the re-budget to be approved by their Dean as the re-budget will have a negative impact on the indirect cost return to the school.

BU researchers often collaborate with people and companies outside of BU. The process to use when entering into an agreement for services depends on the nature of the services and the size and duration of the engagement. Please see information from Accounts Payable for complete guidance on these engagements.
Effective January 8, 2017, under Notice Number: NOT-OD-17-049, the Department of Health and Human Services (DHHS) restricted the amount of direct salary that can be charged to DHHS Sponsored Awards. For FY2018, this rate is $189,600.

Please note that most Faculty are unable to devote 100% of their time to sponsored activities due to other responsibilities that include teaching, administrative work, patient care, competitive proposal writing, and service. Accordingly, unless the circumstances of a particular faculty member demonstrably warrant otherwise, the total effort and salary of a faculty member should normally not be 100% supported by sponsored projects in a given effort period. Such circumstances might include being on sabbatical, leave of absence, or having relief from teaching and other responsibilities. Salary support for time spent on non-sponsored activities must not be charged to sponsored funding sources.

Please refer to the Effort Policy for any questions.

My Grant Expenses is a reporting tool that has been developed specifically for Principal Investigators to provide a consolidated, easy-to-access view of budget and expenditure data for grants in his or her portfolio.
 
Viewing Budgets in the Business Warehouse (BW) can be achieved through several different reports. The most commonly used reports for Departments are the Principal Investigator reports located under the Reporting Tab, Grant Management (Faculty) reports.

One other frequently used report is the Budget vs Actual Report located in the Grants Management (Distributed) folder. This report is mainly used by Central Offices and Departmental Administrators.

As a reminder:

  • All reports show data that is one day old so if you are running a report today, the data that is shown is through yesterday.
  • None of the Business Warehouse reports currently encumber salary, fringe, or indirect charges. Please see your department administrator with any questions.

Subawards

 

A subaward is financial or other support from a prime awardee to a qualified organization for the performance of a significant portion of the research program.

Once a subrecipient agreement has been executed, the subrecipient invoices Boston University on a monthly basis. The subrecipient agreement indicates that all invoices are to be sent to PAFO via email (subinv@bu.edu) where the invoices are re-directed to the appropriate Principal Investigator or Co-PI for review and approval. Each invoice should be reviewed by the PI or Co-PI to ensure that adequate technical progress has been made to support the charges listed. Any issues with the invoice should be brought to the attention of both the department administrator and the PAFO RAResearch Administrator A sponsored programs team member w... responsible for the subrecipient agreement for resolution.

The signature of the PI or Co-PI on the invoice or evidence of PI authorization through other means (such as email) is required. Alternate signatures (e.g. department administrator, graduate research assistant, postdoctoral fellow, etc.) are generally not considered adequate because these individuals generally do not possess full knowledge of the costs incurred in relation to the work performed on the subaward.

Once the PI or Co-PI signs the disbursement form, all paperwork is returned to PAFO via email for further PAFO RA review.

PAFO Review of Invoice includes the following:

  1. Ensure evidence of authorization has been provided by the PI or Co-PI, or another appropriate official through signed invoice or other suitable means (e.g.: email).
  2. Verify that the requested payment falls within the subaward dates.
  3. Ensure the total amount invoiced does not exceed the amount of the subcontract.
  4. If the dates do not fall within the subaward period or if the total amount invoiced exceeds the total amount on the subaward, the invoice cannot be processed. The reviewer should contact the subrecipient to seek clarification. If a modification is needed, Sponsored Programs becomes responsible and the invoice will be held until proper paperwork is in place.
  5. If the invoice meets the criteria of conditions 1, 2, and 3, the current monthly activity is then verified for accuracy. The cumulative balance must be the sum of the current monthly activity and all prior cumulative amounts.
  6. The invoice is reviewed to determine if the expenses are in accordance with the terms and format prescribed in the subaward documents. If there are any unusual charges or changes appearing on the invoice, the administrator will contact the subrecipient for clarification. Any irregularities that are not satisfactorily resolved will be discussed with the PI. In addition, any cost sharing required of a subrecipient is adequately documented on the invoice.
  7. Verify the invoice is sequential (either number or time period). If it is not, this could indicate invoices are missing.
  8. The invoice should be an original, not a copy.
  9. Ensure that an original signature and certification by an authorized financial officer from the subrecipient is documented on the invoice. For subawards of federal funds the signature must accompany the federal certification.
  10. If a subrecipient has not submitted an invoice six (6) months into a budget period, the PAFO RA will contact the PI and the subrecipient and request an update. The timely submission of subrecipient invoices can be a problem in closing out accounts and submitting financial status reports to sponsors, and is an area that requires monitoring.

Once reviewed for accuracy, the PAFO RA signs the disbursement form and submits to Accounts Payable for payment.

All subrecipient invoices are processed through an online Subrecipient Invoice Disbursement Form.

The online Subrecipient Invoice Disbursement Form is accessible through the Forms page on the Accounts Payable website, just like the online Accounts Payable Disbursement Form. You can view the form here and see how it appears on the AP Forms webpage.
 

Approving and submitting the form

  • Subrecipient invoices are sent via email from PAFO (subinv@bu.edu) to Departments and the Principal Investigator or Co-PI for approval.
  • The form will be completed and submitted by Departments and include the subrecipient invoice and Principal Investigator or Co-PI approval as attachments.
  • The Principal Investigator or Co-PI approval will now include either a signature on the invoice or email approval. They will no longer need to sign the Subrecipient Invoice Disbursement Form.
  • The submission will route directly to your PAFO Research Administrator for approval, and thereafter to Accounts Payable for final processing. The submitter also will receive an email confirmation that will include a unique Source Document Number for more simplified tracking.

GL Accounts to use

  • GL Account 517510 for SUBCONTRACTS <$25,000
  • GL Account 517520 for SUBCONTRACTS >$25,000

 
If you have any questions, please contact your PAFO RESEARCH ADMINISTRATOR.

Effort Reporting

Boston University receives substantial funding from the federal government and other sources in the support of sponsored programs. Uniform Guidance requires Educational Institution recipients of federal funding to maintain a system that documents and supports individual distribution of activities and associated payroll charges to sponsored agreements.

Boston University applies these standards to all sponsors through the Personnel Activity Report system. The Personnel Activity Report (PARPersonnel Activity Report You can find details about Per...) system assures external sponsors that funds are properly expended for the salaries and wages of those individuals working on the projects they sponsor. This provides the principal means for certifying that the salaries and wages charged to sponsored projects are consistent, fair, and timely with the effort contributed. Finally, sponsors and auditors must also be able to verify that funds allocated for cost sharing have been provided.

The PAR system is the mechanism the University uses to document cost shared salary expenses. All employees involved in certifying effort must understand that inaccurate, incomplete, or untimely effort reporting could result in financial penalties, funding disallowances, and harm to the reputation of the individual and the University.

Effective January 31, 2018, PAFO will distribute PARs and Control Logs as electronic PDFs via email. PAFO will no longer mail paper PARs.

PARs: Important Dates and Guidelines; Quick Guide to Completing and Returning PARs
Policies: Sponsored Program Effort Certification Procedure; Sponsored Program Salary Adjustment Procedure
CAP Worksheets: 12-month faculty; 9-month faculty
Wage Types
Certain sponsors, most notably NIH, impose a limit or “cap” on the annual rate of salary reimbursement for a given amount of effort. The difference between the reimbursed salary (“capped amount”) and the un-reimbursed salary is considered voluntary committed cost sharing and must be recorded on the Cost Sharing section on the PAR. Please refer to the 12-month faculty or 9-month faculty cap worksheet to assist in calculating cap cost sharing. Use the wage type information to fill out the cap worksheets.

If you are trying to calculate cost share for the PAR period ending June 2018 or prior, please contact effort@bu.edu.

Do I need to cost share salary over the cap?

  • Is my PAR noted “Faculty – Over DHHS Cap?
  • If the answer is yes then, you must report a cost share percentage in “Category II. Section B. Cost Sharing Activity” on the PAR form and reference the DHHS sponsored program number. The cost share percentage will come from the BU Non-Sponsored Activity. The annual “cap amount” for this PAR period is $189,600. Below is an example of how to calculate:

Dr. Smith earns $250,000 annually, expended 50% effort on a DHHS program and 50% effort on Non-Sponsored Activities due to the following tasks: clinical, teaching and proposal writing.

AccountTotal % of Effort$ Charged to Sponsored Program$ Charged to Non-Sponsored ActivityAnnual PAR EffortAnnual PAR Effort to Cost Share
Non-Sponsored Activity50%$125,000 (50% * $250,000)50%
DHHS Sponsored Program #50%$94,800 (50% * $189,600)$30,200 (($250,000 – $189,600) * 50%)38% ($94,800 / $250,000)12% ($30,200 / $250,000)
Total100%$94,800$155,20088%12%
$250,000 = Total Dollars100% = Total Effort

Effective July 1, 2016 PARs are generated twice a year in two unique PAR Periods: January to June and July to December. PARs are separated into three distinct groups: Exempt, Non-Exempt, and Student.

See the Effort Reporting Period Dates

PARs are not generated for students that are paid on a weekly basis using timesheets. Rather, the weekly timesheet serves as their effort certification. Their direct supervisor is designated as a responsible official using suitable means of verification that the hours worked reasonably reflect the actual effort devoted to the sponsored agreement(s).

If you are doing a salary adjustment for an individual who has never been charged to a Sponsored Program before, you must contact Effort Reporting at effort@bu.edu to request a Manual PAR be generated. If you need to report effort for cost share where this individual has not been paid from a sponsored project you must also contact your PAFO RA.

Most faculty are unable to devote 100% of their time to sponsored activities due to other responsibilities that include teaching, administrative work, patient care, competitive proposal writing, and service. Accordingly, unless the circumstances of a particular faculty member demonstrably warrant otherwise, the total effort and salary of a faculty member should normally not be 100% supported by sponsored projects in a given effort period. Such circumstances might include being on sabbatical, leave of absence, or having relief from teaching and other responsibilities. Salary support for time spent on non-sponsored activities must not be charged to sponsored funding sources.

PIs cannot certify 0% effort on a sponsored project during the entire grant funding period. They must certify at least 1% effort on an effort statement during any one of the effort periods to accurately reflect their leadership of the project, unless specifically exempted by the sponsor. Such exemptions may include equipment and instrumentation grants, dissertation and training grants and limited purpose grants such as travel grants and conference support.

Cash Management

 

Cash Management is responsible for all non-student University Billing, both Sponsored and Non-Sponsored. This includes Miscellaneous Receivables and Sponsored Research.

There are three types of billing and eight award statuses in SAP (Boston University’s financial system) as listed below:

Billing Types

  1. Cost Reimbursable
  2. Milestone
  3. Manual

Award Statuses (as listed in SAP)

  1. Approved Award – allows for billing
  2. Pre-Award Billable – allows for billing
  3. Pre-Award Not Billable
  4. Compliance Hold
  5. Department/OSP – allows for billing
  6. PAFO/OSP – allows for billing
  7. Pre-close
  8. Closed

Cost Reimbursable accounts in Approved Award or Pre-Award Billable status that are not ending within the next 30 days are billed in the month following the month that expenses have posted to an account in SAP. If an account becomes overspent in a month, an invoice cannot be generated until the overexpenditure is cleared from the account by one of two ways: moved to a department account or additional funding has been awarded and added to the account.

Accounts that will be ending within 30 days or have recently ended, are billed once the PAFO Research Administrator has confirmed the ending balance with the department administrator and a final invoice summary template has been reviewed and signed by the Billing Supervisor.

Cash Management is also responsible for the collection of outstanding receivables. In some instances, Cash Management requires the assistance of Principal Investigators or the Department Administrator in collecting outstanding receivables.

Please refer to the Escalation of AR Policy located in the Policy Library here.

Miscellaneous Receivables invoices the sales and services rendered by University departments to external entities. See the Miscellaneous Receivables page for more information about invoicing, payments, and collections.

Boston University’s main bank is JPMorgan Chase. For account information, please contact the Director, Cash Management at 617-353-4555.

Common Elements

Commitment closeout is a shared responsibility by Post Award Financial Operations and Department Administrators. Post Award Financial Operations Research Administrators are responsible for closing commitments related to journal entries and fund reservations that are in the 450xxxxxxx series.
 
Journal entry commitments are closed one of two ways: either by approval of the entry or deleting the entry. Fund Reservations are reduced after the final subaward invoice is processed and a balance remains on the fund reservation.
 
Department Administrators are responsible for closing Purchase Order, Shopping Carts, Internal Service Requisitions and fund reservations outside the 450xxxxxxx series. The Department Administrator works with Sourcing to close Purchase Orders and Shopping carts with open balances and they will work with the Internal Service Provider to close any open commitments related to Internal Service Requisitions. The initiator of a fund reservation that is outside the 450xxxxxxx series must close those commitments, typically those are created by the Department Administrator so they would be closed by that person.

For awards that are in a closing status such as PAFO/OSP or CLOSED open commitments can only be cleared if the status is updated. Please contact your PAFO RA to update a status.

Cost Overruns on Sponsored Awards are not allowed and must be removed prior to closeout. This practice was implemented by leadership in 2008 as stated in the memo below.
 

TO: Deans, Department Chairs, Directors, Principal Investigators and Departmental Administrators
FROM: David K. Campbell, Ph.D., Provost, Boston University Karen Antman, M.D., Provost, Medical Campus Martin J. Howard, Vice President for Financial Affairs and Treasurer
SUBJECT: Financial Oversight and Over Expenditure of Sponsored Project Awards
DATE: August 29, 2008

As Boston University’s Sponsored Research activities increase, we must identify and implement more effective management and compliance oversight of research contracts. The regulatory administrative workload associated with documentation and timely agency reporting are daily challenges. Additionally, any awards that are overspent without available grant or department funding create a deficit for the department and the University.

The Principal Investigator (PI) is ultimately responsible for the technical and financial aspects of a sponsored award. In most situations, the PI will work with a departmental business administrator in the financial oversight of the award. PI’s and/or departmental business administrators must review expenditures on awards throughout the life of the award. Review of expenditures is an ongoing process and should not be postponed until the preparation of a final report of expenditures. This review should entail the timely review of accounts, as well as the certification of effort through the Personnel Activity Report (PAR).

With respect to over expenditures of sponsored project budgets, Research Administration (RA) will continue to monitor spending on awards throughout the life of the project. If current expenditures or projected costs exceed the budgeted amount, RA will contact the Department to determine how to fund the overdraft (i.e., imminent additional funding, transfers to remove costs, etc.).

Effective immediately, departments must remove over expenditures within 30 days of notification. If the overdraft is not cleared within 30 days, RA will transfer the overdraft amount to the department, freeze the specific grant account to prevent further expenditures and send a confirmation to the PI and the Department Head.

Thank you for your continued support and fiscal responsibility.

Disposition

Disposition of equipment occurs when an asset is scrapped, sold, lost, stolen, traded-in, returned to vendor, dismantled or otherwise made unavailable to the University. Please note that stolen property must be immediately reported to the Boston University Police Department, Risk Management, and Property Management. The specific type of acquisition determines the appropriate method of disposition. The moveable capital equipment management form is used to complete these functions.

Go to Moveable Capital Equipment procedures

The ability to transfer a sponsored project from Boston University to another institution is dependent upon the regulations and policies of the sponsoring agency and those of BU. Policies vary widely between sponsors, and the PI/PD is strongly encouraged to contact the appropriate Sponsored Programs office (BU or BMC) for specific information as soon as possible after deciding to move to another institution. There are four parties involved in any transfer request: the PI/PD, the original institution, the new institution, and the sponsor. Should the original institution decide not to nominate another PI/PD or to continue the project at the institution, and if the new institution is willing to undertake the administration of the project, the sponsor will usually agree to the transfer. Criteria for this decision include the following:

  • Consideration of the time left on the project.
  • The amount of remaining funds.
  • What, if any, work will remain at BU.
  • Whether the new institution has adequate facilities, equipment, and staff.

The PI/PD should remember that equipment purchased on prior awards or earlier competing segments of the award that is being transferred are the property of the University and may not be transferred to the new institution without specific permission and, occasionally, appropriate compensation for any cost-sharing or alterations/renovations originally required to put the equipment in service. This also applies to equipment included as part of a faculty start-up package.

For an overview of faculty departure procedures please see the Faculty Departure Checklist. For additional information please see “Faculty Departure Procedures” within the Faculty Handbook and School Bylaws section.

Financial Reporting and Closeout is a shared responsibility by Post Award Financial Operations, Principal Investigators, and Department Administrators. This Guidance is applied to all sponsored awards received by Boston University and provides the BU research community information regarding its obligations in providing timely, accurate, and complete financial information to sponsors in the form of interim and final reports. This guidance is also intended to facilitate the timely and accurate closeout of sponsored projects in accordance with both federal and non-federal reporting requirements. Please refer to the section Close Out an Award for additional information.
No-Cost Extensions are requests to extend the termination date of a project without additional funds. Some federal sponsors allow the institutions to approve an extension internally with notification to the sponsor; other sponsors require that a formal request for additional time be submitted for their approval. The timing for such requests varies by sponsor, but should generally be processed at least 30–45 days prior to the scheduled termination date of the project.
 
See our resource page for more information on No Cost Extensions.
Please contact your Sponsored Programs RA to process your no cost extension.
Program Income is gross income directly generated by a supported activity or earned by the institution as a result of an award during the period of the award. The treatment of program income on federal grants is stipulated by the administrative requirements of the awarding agency and depends, in part, on whether the funded project is for research or another approved activity. Similarly, non-federal sponsors may have terms and conditions that govern the treatment of program income.
There are three methods for treating Program Income:

  1. Additive: Program income funds are added to the project’s committed funds by the awarding agency and recipient, thus increasing the amount available to accomplish program objectives (increase in available budget).
  2. Matching: Program income is used to finance the non-federal share of the project (offset to cost-sharing or matching). Program income is used for costs during the project period unless the sponsor authorizes deferral to a later period.
  3. Deductive: Total funds available to the project remain the same and the funds generated through program income are deducted from the financial commitment of the sponsor (offset to sponsor’s funding).

In most cases, a separate account should be established to house program income. This allows accountants to submit reports on program income easily, auditors to review program income for compliance with regulations, and allows PI/PDs to utilize their program income funds (where allowable) to maximum advantage. Whether a separate account is created or not, the following are minimal expectation of PI/PDs and departmental administrators with respect to program income:
PI/PDs are responsible for the following:

  • Identifying sources of actual and potential program income at the proposal stage.
  • Completing required program income sections in the grant proposal as necessary.
  • Developing a plan for using program income.
  • Discussing anticipated program income with the departmental administrator.
  • Verifying program income on reports.
  • Addressing account balance issues at final project termination.

Departmental administrators are responsible for the following:

  • Assisting PI/PD in calculating prices.
  • Billing for products or services which produce program income.
  • Reconciling revenue invoiced or submitted against financial reports.
  • Monitoring levels of program income in the account and any limits that are set by the sponsor.
  • Properly depositing income received in accordance with the University’s revenue policy.
  • Monitoring expenditure levels.

PAFO is responsible for tracking and reporting program income to sponsors

For more information about Travel on Sponsored Awards see here. Post Award Financial Operations follows the BU travel policy.

Guidelines for Direct Charging of Administrative & Clerical Salaries to Federally Sponsored Projects

Per the Office of Management and Budget Uniform Guidance, the salaries of administrative and clerical staff should normally be treated as indirect (F&A) costs and should not be direct charged to sponsored projects. However, under certain conditions, the Guidance does provide criteria where the direct charging of administrative and clerical costs may occur. This guidance document is designed to aid faculty and staff in determining whether it is appropriate to budget for and charge such costs on a specific sponsored project.

 

Criteria for including administrative and clerical salaries in the proposal budget

  • Are the administrative/clerical services integral to a project or activity? Does the project require services that are beyond the routine level normally provided by administrative unit personnel, or by personnel in comparable units?
  • Can the individuals involved be specifically identified with the project or activity and is their effort commitment on average at least 20% (approximately one day per week) during the budget year?

If the answer to each of these questions is yes, then it is acceptable to include the related costs in the proposal budget. Please include the following template statement in the budget justification, tailoring it as necessary to apply to your project:

“This project includes extensive management of [subawards / travel / investigator coordination, etc.] This volume of activity and the tight timeline of the project mandate more extensive monitoring than the services routinely provided by the department. A XX% time administrative / program assistant is needed to oversee the following activities . We are therefore requesting agency approval for a [List % time appointment here] [List position title here] as an administrative cost allowed under 2 CFR 200.413.”

For further assistance with proposal budgeting, please contact your Sponsored Programs Research Administrator.

 

Awards issued after December 26, 2014 are subject to the Uniform Guidance. Per the criteria above, if you receive an award in which these proposed costs were specifically included, they may be charged directly to the award. If such costs have not been included in the proposal and award budget, you will need to obtain prior written approval from the awarding agency in order to direct charge them to the project.
 
This is only guidance regarding the allowability of directly charging administrative support to an award; it is the Principal Investigator’s responsibility to work with his/her Department Chair or Director regarding the necessary non‐sponsored financial support of the administrative personnel.
 
The Uniform Guidance requires institutions to ensure that costs that are direct charged in this nature not be recovered as indirect costs. As part of the development of the Facilities & Administrative rate proposal, Post Award Financial Operations will ensure these costs are excluded to ensure compliance with the Uniform Guidance.
 
The following are examples of circumstances under which it may be appropriate to directly charge sponsored projects for administrative costs:
 

  • Large, complex programs that entail assembling and managing teams of investigators from a number of institutions.
  • Programs that involve extensive data accumulation, analysis and entry, surveying, tabulation, cataloging, searching literature, and reporting.
  • Programs that require travel and meeting arrangements for large numbers of participants, such as conferences and seminars.
  • Programs with a principal focus of preparing and producing manuals and large reports, books and monographs (excluding routine progress and technical reports).
  • Programs that are geographically inaccessible to normal departmental administrative services, such as seagoing research vessels, radio astronomy projects, and other research field sites that are remote from the campus.

For concerns related to Proposal/Budget Preparation and Submission please contact Sponsored Programs at 617‐353‐4365.
For concerns related to Charging Administrative/Clerical Salaries please contact Post Award Financial Operations at 617‐353‐4555

Last Updated: 10/30/14

A subaward is financial or other support from a prime awardee to a qualified organization for the performance of a significant portion of the research program.

Once a subaward agreement has been executed, the subawardee invoices Boston University on a monthly basis. The subrecipient agreement indicates that all invoices are to be sent to PAFO via email where the invoices are re-directed to the appropriate Principal Investigator or Co-PI for review and approval. Each invoice should be reviewed by the PI or Co-PI to ensure that adequate technical progress has been made to support the charges listed. Any issues with the invoice should be brought to the attention of both the department administrator and the PAFO RA responsible for the subrecipient agreement for resolution.

The signature of the PI or Co-PI on the invoice or evidence of PI authorization through other means (such as email) is required. Alternate signatures (e.g. department administrator, graduate research assistant, postdoctoral fellow, etc.) are generally not considered adequate because these individuals generally do not possess full knowledge of the costs incurred in relation to the work performed on the subaward.

Once the PI or Co-PI signs the disbursement form, all paperwork is returned to PAFO via email for further PAFO RA review.

PAFO Review of Invoice includes the following:

  1. Ensure evidence of authorization has been provided by the PI or Co-PI, or another appropriate official through signed invoice or other suitable means (e.g.: email).
  2. Verify that the requested payment falls within the subaward dates.
  3. Ensure the total amount invoiced does not exceed the amount of the subcontract.
  4. If the dates do not fall within the subaward period or if the total amount invoiced exceeds the total amount on the subaward, the invoice cannot be processed. The reviewer should contact the subrecipient to seek clarification. If a modification is needed, Sponsored Programs becomes responsible and the invoice will be held until proper paperwork is in place.
  5. If the invoice meets the criteria of conditions 1, 2, and 3, the current monthly activity is then verified for accuracy. The cumulative balance must be the sum of the current monthly activity and all prior cumulative amounts.
  6. The invoice is reviewed to determine if the expenses are in accordance with the terms and format prescribed in the subaward documents. If there are any unusual charges or changes appearing on the invoice, the administrator will contact the subrecipient for clarification. Any irregularities that are not satisfactorily resolved will be discussed with the PI. In addition, any cost sharing required of a subrecipient is adequately documented on the invoice.
  7. Verify the invoice is sequential (either number or time period). If it is not, this could indicate invoices are missing.
  8. The invoice should be an original, not a copy.
  9. Ensure that an original signature and certification by an authorized financial officer from the subrecipient is documented on the invoice. For subawards of federal funds the signature must accompany the federal certification.
  10. If a subrecipient has not submitted an invoice six (6) months into a budget period, the PAFO RA will contact the PI and the subrecipient and request an update. The timely submission of subrecipient invoices can be a problem in closing out accounts and submitting financial status reports to sponsors, and is an area that requires monitoring.

Once reviewed for accuracy, the PAFO RA signs the disbursement form and submits to Accounts Payable for payment.