Sponsored Project Financial Management and Reporting
Overview
Compliant Fiscal Management of a Sponsored Project
Clemson University supports the efforts of faculty in seeking and securing external funding for the multiple of projects and initiatives that characterize Clemson’s robust research enterprise. A critical component of these activities is ensuring that funded projects are managed according to the sponsor, State of South Carolina and Clemson policies. This section provides an overview of the multiple regulations and requirements for compliant management of a sponsored project.
The federal government has issued multiple guidance in managing a sponsored project. This guidance has generally been adopted by Clemson University for all sponsored projects, except when specific terms and conditions of the award state otherwise. In all instances, Clemson adheres to State of South Carolina regulations and its own policies whenever there is competing guidance from the sponsor, and Clemson policies require stronger restriction.
The Federal Office of Management and Budget (OMB) issues and periodically updates guidance directly related the sponsored projects. This is officially codified in the Code of Federal Regulations (CFR) under the title 2 CFR 200. Refer to the general regulations in 2 CFR 200 relating to sponsored projects.
Project Direct Costs
General Direct costs are those costs that can be identified specifically with a particular final cost objective, such as a Federal award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy.
Direct Costs are itemized costs that are included in the proposal budget and budget justification and awarded as part of the award notification. Direct costs may include salaries and benefits of personnel working on the award, travel directly associated with the project, supplies specifically used on the project, contractual services and subaward costs associated with the project’s research and results, and equipment used to accomplish the aims of the project.
Expenditures charged to a sponsored award must benefit the sponsored project and occur within the projects’ awarded timeframe. Costs cannot be incurred after the expiration of the grant or contract (end date) unless the purchase was made and/or encumbered prior to the grant’s expiration, or the sponsor has authorized an official extension of time that extends the end date of the project.
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2 CFR 200 General Guidance on Costs and Criteria for Allowable Costs
In order for a cost to be charged as a direct cost, it must be an allowable cost to the award. Uniform Guidance §200.403 identifies that costs must meet the following general criteria to be allowable:
- Be necessary and reasonable for the performance of the Federal award and be allocable under these principles.
- Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
- Be consistent with policies and procedures that apply uniformly to both federally and non-federal activities of the University.
- Be accorded consistent treatment (a cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost).
- Be determined in accordance with generally accepted accounting principles (GAAP).
- Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period.
- Be adequately documented (see also §§200.300 Statutory and national policy requirements through 200.309 Period of performance of this part. Costs must be necessary and reasonable for the performance of the award and be allocable to the award).
Charging Personnel on Sponsored Projects
The largest category of direct expense on a sponsored project are typically personnel costs. The principal investigator (PI) is responsible for ensuring that personnel performing work for the sponsored project is appropriately charged and the proportionate amount of salaries charged accurately reflects the work performed.
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Salary Basis
Charges for work performed on sponsored projects during the academic year are allowable at the Institutions base salary (IBS) rate and based on the individual’s regular base compensation. In no event should charges to sponsored projects, irrespective of the basis of computation, exceed the proportionate share of the base salary for that period. See Clemson’s Institutional Base Salary (IBS) policy for additional information on what is included and excluded for the IBS calculation. Further, charges for work performed by faculty members on sponsored agreements during the summer months will be determined for each faculty member at a rate that is not in excess of their base salary. The base salary period used in computing charges for work performed during the summer months will be the number of months covered by the faculty member’s official academic year appointment. For example, if a PI works on a sponsored project for one month during the summer, the maximum amount of salary chargeable to the project is one-ninth of the academic year salary, assuming the academic year appointment is nine months.
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Initiating Pay for Personnel on a Sponsored Project
Once an award has been received by the institution or Risk Project has been requested, college or departmental grants administration personnel should meet with the principal investigator to review proposed project personnel and identify those individuals who will be working on the sponsored project. A Fund 20 Sponsored Project Number and chartfield string will be provided by Office of Grants and Contracts Administration (GCA) once the award document has been reviewed by the Office of Sponsored Programs (OSP) and all regulatory requirements [i.e. Conflicts of Interest (COI), Institutional Review Board (IRB) and Institutional Animal Care and Use Committee (IACUC), when applicable] have been met.
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Amending Pay for Personnel on Sponsored Projects
When a principal investigator manages multiple ongoing projects, the distribution of salaries of the PI, research assistants, postdocs, graduate students and other staff to the various projects must be carefully reviewed and adjusted as changes occur. Salary for personnel on sponsored projects must be reasonable, and commensurate with the work performed. As the need for changes to personnel charged to sponsored projects arise, please contact your Department or College HR/Post-award administrator to amend and approve changes via the Earning Distribution form for personnel charged on sponsored projects.
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Changes to Posted Payroll Transactions
Changes to payroll transactions that have already posted must follow the University payroll correction (PRC) policy and procedure. When changes involve corrections to a sponsored project, the university cost transfer policy applies. Transfers involving sponsored projects should be performed within 90 days of the original transaction posting date. Timely corrections ensure that future reviews and approvals of sponsored reports are accurate at the time of review. PI’s should contact their department or college post award personnel for assistance.
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Sponsor Salary Caps and Salary Limitations
Some sponsors may choose to limit the salary or cap the rate at a maximum level:
HHS Agencies: Congress has limited the salary that an individual may receive under certain federal awards (DHHS/NIH/AHRQ/SAMHSA/CDC/HRSA). The salary cap is linked to the federal Executive Level II executive pay scale and is adjusted whenever federal salaries are increased. This typically occurs in January of each year. Please click the link to learn more on the HHS Salary Cap restrictions.
NSF: “As a general policy, NSF limits the salary compensation requested in the proposal budget for senior personnel to no more than two months of their regular salary in any one year. It is the organization's responsibility to define and consistently apply the term "year", and to specify this definition in the budget justification. This limit includes salary compensation received from all NSF-funded grants. This effort must be documented in accordance with 2 CFR § 200, Subpart E, including 2 CFR § 200.430(i). If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice budget.” For the purposes of this guidance, Clemson has determined that the term “year” applies to the Clemson fiscal year – July 1 through June 30.
In these cases, any salary that exceeds the limitation or proportionate share over the cap is an unallowable expense on the sponsored project.
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Administrative and Clerical Costs
In accordance with 2 CFR § 200.413, the salaries of administrative and clerical staff should normally be treated as indirect costs (F&A). Direct charging of these costs may be appropriate only if all the conditions identified below are met:
- Administrative or clerical services are integral to a project or activity;
- Individuals involved can be specifically identified with the project or activity;
- The costs are not also recovered as indirect costs.
Participant Support Costs
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance, 2 CFR 200.75) defines participant support costs as direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects. Participant Support costs are made in connection with conferences or training projects and are exempt from F&A. Sponsor guidelines typically dictate when participant support should be included in the project budget. Human subjects are not considered trainees, although they may sometimes be referred to as participants. Research incentives paid to human subjects are not exempt from F&A. See your College Post-Award Contact (CPAC) with any questions.
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More Information
A participant is NOT:
- A Clemson University employee
- A student or project staff member receiving compensation directly or indirectly from the sponsored project
- A recipient of compensation from any other federal government source while participating in the project
- The same as a research subject receiving incentive payments
Participant Support (PARTSP) Account Codes:
7550 — Part Supp-Incentive Cards
A card purchased from National Gift Card via CU buyWays to present to individuals for participation in an externally funded sponsored project (fund 20) which is budgeted in the Participant Support category7551 — Part Supp-Reimbursable Exp
Reimbursed expenditures (for example: participant mileage/housing/lodging, participant-related supplies)7552 — Part Supp-NonReimb
Non-reimbursed expenditures (for example: stipend payments)7553 — Part Supp-NonReimb-Foreign Nat
Non-reimbursed expenditures to participants who are foreign nationals7560 — Part Supp-REU Program
Specifically used for REU grant participants
Other Costing Guidance
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Telephone, Cellular and Internet Services
Generally, these costs must be specifically justified and included in the project budget. There must be a well documented reasons that these services are not available to the project under normal circumstances.
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Travel Costs
Sponsors may have specific guidance for travel costs. Consult 2 CFR 200.475 and/or the award document for restrictions and consult the Clemson University travel policy page for additional assistance.
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Travel Costs – International Travel
When a sponsored project has included and received approval for International/Foreign travel, the traveler must submit and obtain advance approval through Clemson prior to the purchase of tickets or any other pre-travel expenses. The traveler must complete the form: "Authorization for Official International Travel". When completed and department, college, and export control signatures are secured, this form should be submitted to Grants and Contracts Administration for approval. Please note that travel to Canada, Puerto Rico, and the Virgin Islands are not classified as foreign travel, however a Foreign Travel form is still needed for export control approval.
View the Federal Fly America and Open Skies Regulations for more information.
