Author: Dr. Edwin Bemmel, AVP, RGC
We are excited to share that our policies have been released into Policy Manager. These policies were created with feedback from our stakeholders and are based on the Uniform Guidance and standard grants management practices. While most are new, several are revisions of existing policies. Here is a listing of the policies with a link and overview of each.
Cost Transfers and Payroll Reallocations: www.policies.emory.edu/2.125
This policy is intended to process cost transfers in accordance with 2 CFR 200, Federal and State regulations, and other agency-specific requirements. All necessary adjustments must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. If an individual agreement or sponsor has more restrictive requirements than this policy, the more restrictive practice must be followed.
This is a codification of requirements set by the Uniform Guidance and sponsors’ award administration standards and is created to set and communicate standard award management practices at Emory University. This policy will assist with creating consistency and demonstrate strong internal controls to auditors.
Sponsored Award Overrun and Unallowable Cost Policy: www.policies.emory.edu/7.27
This policy addresses the management of overruns and unallowable cost related to sponsored award administration at Emory University. Overruns and unallowable cost must be addressed in a timely, consistent fashion to ensure proper stewardship of sponsored award funds in accordance with regulations outlined in OMB 2 CFR 200 (Uniform Guidance) and other applicable sponsor requirements.
Small Balance Write-Off Policy: www.policies.emory.edu/7.35
This Small Balance Write-Off Policy seeks to promote robust financial management by defining when minor revenue and expenses can be written off to an appropriate departmental account. This policy promotes efficient and proper stewardship of sponsored award funds in accordance with regulations outlined in OMB 2 CFR 200 (Uniform Guidance) and other applicable sponsor requirements.
Residual Balance Transfer Policy: www.policies.emory.edu/7.36
This Residual Balance Transfer Policy sets forth the final disposition of unexpended residual balances related to fixed price, fixed rate, or nonrefundable agreements managed by Emory University. This policy promotes efficient and proper stewardship of sponsored award funds in accordance with regulations outlined in OMB 2 CFR 200 (Uniform Guidance) and other applicable sponsor requirements.
Sponsored Award Close Out Policy: www.policies.emory.edu/7.37
This policy addresses the management of award closeout related to sponsored award administration at Emory University. Award closeouts must be addressed in a timely, consistent fashion to ensure proper stewardship of sponsored award funds in accordance with regulations outlined in OMB 2 CFR 200 (Uniform Guidance) and other applicable sponsor requirements.
Allocation Methodology for Sponsored Programs: www.policies.emory.edu/7.39
This policy is intended to provide guidance for the allocation of costs that benefit two or more projects or activities. Allocations are necessary when assigning recurring or direct costs to sponsored projects and must be done so in alignment with relative benefit. Costs should also be assigned with a relatively high degree of accuracy. Compliance under this policy is required by 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and federal regulations pertaining to Cost Accounting Standards (CAS).
Program Income: www.policies.emory.edu/7.40
This policy is intended to account for program income in accordance with 2 CFR 200, Federal, and State regulations, and other agency specific requirements. Emory University will comply with all requirements related to income generated as a result of a sponsored award during the period of performance and will provide cost effective controls to account for program income in accordance with 2 CFR 200 and other agency specific requirements.
Provisional Award Number (PAN): www.policies.emory.edu/7.41
This policy is intended to provide guidance when establishing a Provisional Award Number (PAN) is allowable prior to receiving an official award document if certain criteria are met. A PAN allows the PI/PD to spend funds before the sponsor issues a formal award document or the university accepts the award. When the award is fully executed and all necessary compliance matters resolved, the award will be fully set up in Compass with the same SpeedType(s) set up for the PAN.
Supplemental Pay for Sponsored Programs Policy: www.policies.emory.edu/7.42
The Supplemental pay policy is established to expedite and facilitate certain salary payments for monthly paid employees. Supplemental payments include extra duty pay, bonuses, honorariums, and award payments. Supplemental pay processed on sponsored programs may trigger specific review to ensure that payment outside of normal salary distributions is allowable according to the sponsor’s award terms and conditions. Supplemental compensation can only be charged to federally funded awards in special cases where it has been specifically authorized (prior approval) by the awarding agency.
Budget Revisions: www.policies.emory.edu/7.43
This policy is intended to account for budget revisions in accordance with 2 CFR 200, Federal, and State regulations, and other agency specific requirements. The budget for a sponsored project is the financial expression of the project or program as approved during the award process. After a grant or contract has been awarded, the Principal Investigator (PI) may determine that the approved budget allocations are not consistent with the actual needs of the project or program. In such cases, a reallocation of funds from one budget category to another category must occur. This process is called budget revision or re-budgeting.
Capital Equipment: Policywww.policies.emory.edu/7.44
This policy is intended to account for capital equipment purchases in accordance with 2 CFR 200, Federal, and State regulations, and other agency-specific requirements. Emory University will comply with all requirements related to equipment purchased with sponsored funds and will provide cost-effective controls to account for capital equipment purchased with sponsored funds in accordance with 2 CFR 200 and other agency-specific requirements. This policy is to be read in conjunction with and is supplemental to University policies that address Equipment issued by the Controller’s Office
Cost Principles for Federal and Non-Federal Sponsored Programs: www.policies.emory.edu/7.45
This policy is intended to provide guidance on the appropriate budgeting and expenditure application of sponsored program funding whether the primary source is from federal or non-federal sources. This includes but is not limited to research, training, instructional or other purposes. This policy is in alignment with 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). In addition, all applications of expenditures must comply with all applicable Emory University polices, standard operating procedures and guidelines.
Institutional Base Salary: www.policies.emory.edu/7.46
This policy is intended to provide guidance for determining the Institutional Base Salary used on sponsored awards and in accordance with 2 CFR 200, Federal, and State regulations, and other agency specific requirements.
Internal Controls Policy: www.policies.emory.edu/7.47
This policy is intended to document internal controls of sponsored awards in accordance with 2 CFR 200, Federal, and State regulations, and other agency specific requirements.
Invoicing and Financial Reporting Policy: www.policies.emory.edu/7.48
This policy is intended to establish billing and financial reporting requirements in accordance with 2 CFR 200, Federal and State regulations, and other agency specific requirements.
No Cost Extension Policy: www.policies.emory.edu/7.49
This policy is intended to establish guidelines for requesting no cost extensions in accordance with 2 CFR 200, Federal and State regulations, and other agency specific requirements.
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