Direct Charging Policy
Post Award Staff Responsibilities
In accepting federal funds for sponsored projects Brown University agrees to abide by government regulations regarding the use of those funds. The Direct Charging Guidelines serves to provide guidance to meet the compliance standards for defining, charging and accounting for direct and facilities and administrative (F&A or indirect) costs to sponsored awards.
The Direct Charging Guidelines follow the Office of Management and Budget (OMB) Uniform Guidance for any Notice of Award issued to Brown University on or after December 26, 2014. Any awards issued prior to this date will follow OMB Circular A‐21: Cost Principles for Educational Institutions. Notices of awards issued to Brown University after December 26, 2014 will state in the Terms and Conditions section whether the award is subject to Uniform Guidance.
The purpose of this policy is to provide the institutional standard for determining how direct costs are budgeted in proposals and charged to grants, contracts, and other sponsored awards.
The subrecipient is instructed to e-mail invoices (not more frequently than monthly) directly to the responsible Principal Investigator (PI) and Department Administrator. The PI is responsible for reviewing and approving the invoices and concurrently monitoring the activities of subrecipients, as necessary, to ensure that federal awards are being used for their authorized purpose and that performance goals are achieved.
Subaward modifications are used to extend the period of performance, to increase the funded amount to append additional tasks to the Scope of Work, or modify other terms and conditions.
When a prime award, that includes subcontracts, is modified, a modification to the subaward(s) may be required. The Pre-Award Contract Administrator will notify the department via e-mail (as indicated in the section on new subawards) and request that the department submit a Change Order to OSP. The Change Order should indicate how the subaward should be modified.
For a more comprehensive overview of the subaward process can be found on the Subaward Lifecycle webpage.
When closing a subaward, please complete the Subaward Close-Out Certification Form.
The Post-Award team manages the cash-related activities of Brown’s sponsored projects. The goal is to maintain appropriate levels of cash flow for Brown’s sponsored projects while ensuring financial compliance with Federal regulations, sponsor requirements, and University policies.
Essential responsibilities include:
Process Letter-of-Credit (LOC) cash draws and web-based invoicing for Federal awards.
Prepare and file the quarterly Federal Financial Report (FFR) for the LOC awards, and perform funding, cash and expenditure reconciliations.
Process installment or cost reimbursement invoices for Non-Federal or Federal Pass-Through grants and contracts and act as the point of contact for billing inquiries.
Process receipts of sponsor payments and ensure they are credited to the correct award and invoice.
Track sponsored project receivables and initiate collection communication.
Reconcile sponsored project receivable and follow up on unbillable issues.
The shifting of previously incurred costs from one account to another, i.e. Cost Transfers, continue to be one of the top audit risks for sponsored awards and are frequently cited in financial audits of Higher Education institutions across the nation. Below are links to the Cost Transfer Policy and Cost Transfer Explanation and Justification Form. These documents will assist preparers and approvers with the tools necessary to identify the elements critically important for their cost transfers submission and how to properly document and justify the transfer of an expense to a sponsored award.
The goal of the Financial Reporting is to provide Principal Investigators and department administrators with quality support services and financial compliance guidance along with effective stewardship of sponsored awards.
Most sponsors require financial reporting to determine the use of sponsored funds on either a monthly, quarterly, annual or other reporting basis. The Post-Award team is responsible for ensuring that the deadlines for financial reporting are met and that we are in compliance with the federal, state, sponsor specific and/or Brown University’s policies and procedures depending on the type of award. Brown University shall submit timely financial reports to the sponsors of research and other scholarly activity that:
Accurately reflect the actual use of sponsored funds as recorded in the financial records of the University
Ensure that all reports are in compliance with the sponsor’s terms and conditions
Each department is assigned a Grant/Contract Accountant from OSP that will provide guidance and assistance as well as answer any questions that may arise on a day to day basis.
At the conclusion of the award, after the financial report is filed with the sponsor, and all financial obligations are satisfied, the Grant/Contract Accountant is responsible for closing the award within the University’s financial system.
The University must ensure that cost sharing requirements of sponsored agreements are proposed, approved, accounted for, and reported in a manner consistent with the requirements of the sponsor and the University. Cost sharing can be of the following types: Mandatory, Voluntary committed, Voluntary uncommitted, Matching and In-kind. Mandatory, voluntary committed cost sharing, matching and in-kind must be identified, administered and accounted for consistently throughout the University.
The Cost Sharing Policy establishes requirements for the identification, approval, funding, accounting and reporting of mandatory and voluntary committed cost sharing, matching, and in-kind requirements associated with sponsored projects. Cost sharing represents a binding obligation of the University once the award has been granted.
The Cost Sharing Policy provides information on:
The definition and types of cost sharing
The contractual, financial, and administrative implications that result from a commitment to cost share
The cost sharing approval process, including the circumstances in which cost sharing is permitted by the University
Allowable sources of funds for cost sharing
Allowable cost sharing expenditures (i.e., Direct and Facilities and Administrative (F&A) Costs)
The criteria for allowable and unallowable cost sharing expenditures
The roles and responsibilities of University departments and offices with respect to cost sharing
The Office of Management and Budgets’ (OMB) Uniform Guidance: Cost Principles, Audit, and Administrative Requirements for Federal Awards includes regulatory requirements for the planning, confirmation, and certification of effort associated with Federal organized research projects and other activities. Effort directly charged to sponsored projects and any mandatory cost shared effort (i.e. committed effort that is not directly charged to the award) must be identified in the University’s effort distribution/reporting system. The principles that govern how the University must document time and effort on federal awards are in OMB Uniform Guidance. The Uniform Guidance requires each grantee to maintain a system of distributing salary charges to federal awards that results in a reasonable allocation of salary charges to each award. The salary distribution system also must include a periodic review to confirm the reasonableness of salary charges to the federal projects.
The University employs an After-the-Fact effort reporting system that provides the principal means for certifying that the salaries charged or contributed to sponsored projects are reasonable and consistent with the portion of total professional activity committed to the projects.
The following categories of University employees are certified on University generated reports:
All faculty, graduate students, and administrative and professional employees paid on sponsored projects (Frequency - Semi-annually)
Non-exempt support staff, undergraduate students, and limited duration employees paid on sponsored projects (Frequency - Monthly)
As part of the budget appropriations of the National Institutes of Health (NIH), Substance Abuse and Mental Health Services Administration (SAMHSA), and Agency for Healthcare Research and Quality (AHRQ), the US Congress legislatively mandates a salary cap. The salary cap applies to grants, cooperative agreements and contracts (with the exception of those that are clearly defined to be exempt from the cap). Click HERE to view the salary cap for current and previous years. The salary cap limits the rate of academic and summer salary that may be charged to NIH, SAMHSA, and AHRQ awards.
Brown University considers academic or calendar year salary in excess of the imposed cap as mandatory cost sharing. The amount in excess of the cap cannot be used as matching funds. The University may pay an employee’s salary amount in excess of the salary cap from non-sponsored project funds. Salary in excess of the NIH Salary Cap is considered mandatory cost sharing and should be identified during the proposal phase of an award. Refer to Cost Sharing on Sponsored Projects Policy (300.0).
Summer salary is defined as any compensation paid during the summer period to a faculty member in excess of his or her academic year salary. The summer period is defined to be the period outside Institutional Base Salary of the academic year appointment.
A request for summer salary indicates a commitment to put forth the comparable effort on the particular project(s) during the summer, not the academic year. Effort expended during the academic year does not satisfy a commitment related to the receipt of summer salary.
All effort devoted and corresponding salary charged to sponsored projects must be in compliance with sponsor and University policies. Committed effort on a sponsored project should be devoted exclusively to the activity supported by that sponsored project. Other activities performed during the summer months, e.g. any administrative or academic activities, vacation, writing new proposals, may not be charged to sponsored projects. Note that sponsors may have restrictions on summer salary. Faculty should therefore consult their grant terms and conditions prior to committing summer effort. Any questions regarding sponsor terms or conditions should be directed to the Office of Sponsored Projects.
When processing a costing allocation in Workday, please complete and attach the Summer Salary Costing Allocation Template.
Post-Award Staff in the Office of Sponsored Projects is responsible for:
Establishing and monitoring sponsored research accounts
Monitoring expenditure activities on sponsored research accounts to ensure compliance with federal regulations, agency specific requirements, and University policies and procedures
Interpreting, discussing, and applying sponsor regulations and policies
Preparing interim and final financial reports in a timely manner
Cash management of sponsored projects
Disseminating information to principal investigators and administrators on a range of topics related to post-award administration