Scope
This procedure addresses how the University ensures internal controls over expenses that could be charged to sponsored programs.
Responsibility
School/Departmental Grant Managers are responsible for:
- Reviewing expenses for compliance with sponsor and University requirements before submitting charges to an award or grant.
The Office of Sponsored Programs (OSP) is responsible for:
- Assigning the Spend Restrictions during award setup.
The Director of Post Award in the Office of Sponsored Programs is responsible for:
- Ensuring the application of Spend Restrictions to sponsored research awards.
Procedure Steps
Spend Restrictions either allow or disallow expenses being charged to sponsored programs. The Office of Sponsored Programs assigns the Spend Restrictions while setting up the Award and Grant/s based on the terms and conditions of the sponsor, award and usage of the grant worktag. For example, for a basic research award issued by a federal sponsor, the Spend Restriction is Allowable Cost Schedule-Federal, which disallows spend categories that cannot be charged to a federal award. The grant also carries Unallowable Spend Restrictions to ensure that unallocable spend categories would not be charged to the grant (e.g., Fellowship expenses on a research program without a training component). If the award to the University has an outgoing subaward, a separate grant is set up for the subaward, with Spend Restriction “Allowable Subaward” that only allows the subaward spend category to be charged to the grant worktag.
There could be exceptional circumstances where an expense that is not included as allowable in the Spend Restriction but has sponsor approval to be charged to a sponsored award. In such situations, Award Modification Requests should be submitted in ResearchUVA PBH system, for review and modification of existing Spend Restrictions by the responsible Post Award Grant Manager.
The Workday "View Spend Restriction" report shows the spend categories that are allowed or disallowed in a Spend Restriction. The Workday "FDM-Grants-Allowed Spend Categories" report shows allowed spend categories on a selected grant, which is particularly helpful while encountering errors during initiation of transactions (e.g., creating a purchase requisition).
Note: Spend Restrictions are the first layer of internal controls using the financial system, however, before charging expenses, pre transactional reviews by the departmental grant managers are essential to ensure compliance with sponsor and university requirements. The Spend Restrictions must not be taken as the sole means of ensuring internal control of expenses posting on sponsored programs.
Ownership
The Executive Director of the Office of Sponsored Programs is responsible for ensuring that this procedure is necessary, reflects actual practice, and supports University policy.