Grants, Contracts and Sponsored Projects require a large amount of compliance and administration. At ESU, OSPR is able to assist with much of it, but Principal Investigators should have an understanding of how to make sure their project remains compliant.
All grant-related activities must be legal at both the state and federal level. At the federal level, the Office of Management and Budget (http://www.whitehouse.gov/omb/financial_offm_circulars/) issues circulars, three of which are specifically related to grants, contracts and sponsored projects and Institutions of Higher Education.
- 2 CFR Parts 215 and 220 - Cost Principles for Educational Institutions (formerly OMB Circular A-21) - Explains Allowable and unallowable expense
- 2 CFR Part 215 – Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education…and other Non-Profit Organizations (formerly OMB Circular A-110) - Explains policies and procedures that must be in place at the federal and institutional level in order to enter into an agreement (contract, grant, other project) - Outlines regulations for cost sharing - Outlines budget and/or other changes that require agency approval
- OMB Circular A-133 – Audits of States, Local Governments, and Non-Profit Organizations - Mandates audit requirements for organizations that spend over $500,000 in federal dollars in any given fiscal year.
Nearly every federal project will be managed, on the government side, by a specific agency. Each agency, (National Science Foundation or US Department of Education e.g.) has its own requirements and guidelines that must be followed.
Sometimes federal money will be administered at the State Level (by the PA Department of Community and Economic Development or PA State System of Higher Education (PASSHE) e.g.). These agencies, too, have rules and regulations with which a funded project must comply.
Once money comes to ESU, regardless of whether it comes from a federal, state or private source, it is considered ESU’s money and then can only be expensed in accordance with regulations regarding the use of public funds. Grant funded projects must also comply with the University’s procurement, hiring and travel procedures in addition to any other organizational practices followed by the University.
Finally, the grant contract itself may outline allowable expenses, reporting requirements and other regulations specific to that grant. If the grant comes from a private foundation, the foundation may have guidelines on allowable expenses, reporting requirements and other grant or funder-specific requirements.