Grants- Spending Authority
Date: 22 July 2009
Procedure #: 600.080
Written By: Ralph Earhart Director, Financial Services
Grants-
Spending Authority
1.0 Introduction
A. Grants are awarded to The
Citadel for work to be conducted under the supervision of a Principal
Investigator. The Principal Investigator is generally a faculty member.
B. The Principal Investigator
generally submits a budget along with the grant application. In the budget the
faculty member explains how the funds will be spent.
C. Different grantors have
different rules with respect to rebudgeting grant funds. The Citadel
expects that principal investigators are familiar with the terms and conditions
of their grants. The Grant Accountant can assist
Principal Investigators in determining the rebudgeting requirements when
rebudgeting is needed. It is the Principal Investigator who must seek
permission for the rebudgeting, if required. All approvals for rebudgeting must
be received in writing and a copy provided to the Grant Accountant who will put
the approval in the grant folder.
D. The Citadel has no review
mechanism to check behind a Principal Investigator to confirm that the
investigator spent the funds awarded for the items indicated in the grant
application. It is the
responsibility of the Principal Investigator to bring issues related to
allowability of charges or rebudgeting issues to the Grant Accountant.
2. Policy
A. Principal Investigators are
aware of the items requested in a grant application. They are responsible for
proper completion of the grant and have the professionalism to make every
attempt possible to complete the grant, making any adjustments in actual items
to be bought as the situation dictates. The Principal Investigator is
responsible for the proper spending of grant funds. The Principal Investigator
should understand the concept of the action he is to take when funds are
awarded and that person has the knowledge to make adjustments to items noted in
the grant application.
B. It is the Principal
Investigators responsibility to send any questions concerning the proper
spending of funds to the grantor prior to making an expenditure which might be
questionable if an outside person reviewed the spending on a grant.
C. The Grant Accountant can be a
valuable resource with questions related to allowability of expenses or
rebudgeting. The Principal Investigator should contact the grant Accountant is
he has any concern about the appropriateness of a transaction.
D. The Principal Investigator
should seek assistance from the Grant Accountant in order to assume that the
following transactions are appropriate for grants:
1.
Cost transfers to a grant must always be well documented. If a cost was not
initially charged to a grant, then College policy requires certain steps be
taken and documented in order to confirm the cost transfer to the grant is
appropriate. (Please see the “Cost Transfer “policy.)
2.
Spending at the end of a grant period. Grants,
especially federal grants, are provided for specific projects and the work is
to take place during the approved budget periods of the project. In most cases, when a project is closing
down, especially a multi period project, spending during the last 90 days of
the project should generally be limited to closing down the grant and
publishing the results. Buying a year’s worth of supplies in the last month is
inappropriate, since only the expenses related to the actual budget period are
allowable on federal grants. Buying equipment, whether major to minor equipment
during the last 90 days would be unique, since federal rules anticipate that
the equipment should be bought for the specific project, and the necessity for
buying in the final months is suspect.
The message the federal government sends is: “Charges for grants need to
be for expenses incurred during the budget period. Spending at the end of the
grant can be viewed as an inappropriate activity designed to use up available
grant funds resulting in expenditures on the grant for something other than the
grant during its budget period. If a
grant activity continues after the grant ends, it is up to another fund source
to support the activity after the final budget period ends.”
1.0 Introduction
Federal regulations require that charges to federal grants and contracts be “reasonable, allowable, and allocable”. Grants are awarded to The Citadel for work to be conducted under the supervision of a Principal Investigator. The Principal Investigator is generally a faculty member. The Principal Investigator generally submits a budget along with the grant application. In the budget the faculty member explains how the funds will be spent. Different grantors have different rules with respect to rebudgeting grant funds. The Grant Accountant can assist Principal Investigators in determining the rebudgeting requirements when rebudgeting is needed. It is the Principal Investigator who must seek permission for the rebudgeting, if required. All approvals for rebudgeting must be received in writing and a copy provided to the Grant Accountant who will put the approval in the grant folder. . The Citadel expects that Principal Investigators are familiar with the budget requirements of their grants. The College does not review grant purchases to determine if the Principal Investigator is following grant terms.
2. Policy
A. Principal Investigators are responsible to ensure that all charges to a grant or contract are reasonable, allowable, and allocable. The Principal Investigator is aware of the items requested in a grant application is responsible for all charges to the grant. They are responsible for proper completion of the grant and have the professionalism to make every attempt possible to complete the grant, making any adjustments in actual items to be bought as the situation dictates. The Principal Investigator is responsible for the proper spending of grant funds. The Principal Investigator should understand the concept of the action he is to take when funds are awarded and that person has the knowledge to make adjustments to items noted in the grant application.
B. It is the Principal Investigators responsibility to send any questions concerning the proper spending of funds to the grantor prior to making an expenditure which might be questionable if an outside person reviewed the spending on a grant.