Policies & Instructions
Financial management of awards is a responsibility assumed by PI’s/PD’s and the University that is inherent in all projects. PI’s/PD’s and all who support the projects must adhere to the University’s policies and procedures as well as any additional requirements stipulated by sponsors in managing personnel costs, allowable cost principles, cost policies, cost sharing, cost transfers, and audits.
The University has established systems of internal control for the financial management of awards and these controls are subject to review by the USNH Internal Auditor. PI’s/PD’s are responsible for regular financial oversight including documenting approval of costs to awards and review of monthly budget to actual financial reports. Federal awards to the University are subjected to OMB Circular A-133 audit tests and occasionally to additional financial reviews by sponsors.
Compensation and fringe benefit costs are a substantial portion of most sponsored award budgets, therefore managing these costs receives significant attention in managing an award. Appointment letters and documents are important to substantiate the time and effort work plan and labor cost distribution to awards. Time and effort reporting and certification are federal and University policy requirements to substantiate allocations of compensation fairly to the benefit of projects. University policies on regular compensation and additional pay are especially important in meeting requirements of federal awards for allocations of compensation and salary rates. The University has established procedures and forms for requesting additional pay for charges to sponsored awards. Refer to UNH Human Resources policies, forms and procedures on additional pay.
Summer and Supplemental Pay
This guidance is provided for faculty who choose to devote effort and receive compensation from sponsored projects during the summer or as supplemental pay.
Cost Principles and Policies
Award budgets, sponsor terms and conditions, OMB Circular A-21 Cost Principles for Educational Institutions and Uniform Guidance, provide direction to those managing an award when determining allowable cost allocations to an award. Costs are allowable if (1) they are reasonable, (2) they are allocable and provide a fair benefit to the project objectives, and (3) there is consistent cost allocation throughout the University. Costs are allocable to a project if the goods or services involved are chargeable or assignable to the project in accordance with relative benefits received.
This matrix is a handy reference tool for use on awards subject to Uniform Guidance. The matrix will be updated as new Research Terms and Conditions become available.
Cost Accounting Standards Disclosure Statement (DS-2) defines the University cost principles and is filed with the US Department of Health and Human Services, the University’s federal cognizant agency. These cost principles define costs that are appropriate as a direct cost to an award and costs that are consistently included in the indirect cost pool. The DS-2 defines the University’s systems for certifying time and effort.
Cost sharing is that portion of "allowable" externally sponsored program costs not borne by the sponsor. "Matching" is a form of cost sharing often characterized by a required ratio (e.g., 1:1) of cost sharing to sponsor supported costs. The distinction between cost sharing and matching is not as important as the management and accounting for these project costs. When cost sharing or matching is provided through expenditure of other funding sources by the University the supporting documentation is based on cash outlays and recorded in project funds (15C funds). When the cost sharing or matching is provided through third party expenditures on behalf of the project, the substantiation of the value of the cost sharing or matching must be accepted by the University. In-kind cost sharing or matching contributions are donated services, use of non-University equipment, or space, that do not require any cash outlay therefore require special care in substantiating the values. The most important source of information on nonfederal cost shares can be found in OMB Circular A-110 and Uniform Guidance. Refer to the University policy and procedures on cost sharing.
Cost transfers between grants and funds are a common and acceptable accounting practice in research universities and also subject to federal audit scrutiny. Timely cost transfers to correct accounting errors and distribute costs are generally appropriate. Cost transfers not completed within 90 days of the original transaction date recording the expense require central office (SPA, Cooperative Extension, or Ag Experimentation Station), approvals as federal sponsors have determined that cost transfers completed more than 90 days after the original expense transaction are a risk of an unallowable cost. Transfers from one project to another or from one competitive segment to another solely to cover cost overruns are not allowable.
Refer to the University’s policy on cost transfers.
Federal awards are subjected to independent audit tests on an annual or bi-annual basis. The office of Sponsored Program Administration coordinates the OMB Circular A-133 audit activities for USNH. A-133 audit reports must be submitted to the Federal Clearinghouse within 30 days after receipt but not later than nine months after the University fiscal year end (due not later than March 31). http://harvester.census.gov/sac/
The most recent A-133 report is available on the USNH website.
USNH Annual reports
The University is a component institution of the University System of New Hampshire and the annual financial statements of the University are included in the USNH annual reports.
The University of New Hampshire is committed to ensuring employees are not subject to reprisals for “whistleblowing” alleged mismanagement or abuse related to a Federal contract or grant.
Claims of alleged misconduct can be submitted anonymously at the USNH Internal Audit Anonymous Hotline at http://www.usnh.edu/internal-audit/anonymous-hotline.
On the Durham campus, claims also can be submitted to Human Resources (862-0501) and Sponsored Programs Administration (862-2001).