Expenditure Processing
1. Signature Authorization
2. Additional Authorization (One-Up Signature) Policy
3. Criteria for Determining the Allowability of Expenditures
4. Cost-Transfers, Payroll Redistribution or Reallocation of Charges
5. Specialized Categories of Expenditures
1. Signature Authorization
The principal investigator is responsible for complying with the financial and administrative policies and procedures of each award and has exclusive authority to incur expenses against the award. The PI also has the authority to designate this authority to an SDSU or SDSU Research Foundation staff member to assist in the management of sponsored project(s). This authorization enables an individual to approve requests for personnel actions, initiate and authorize expenditures including establish purchase orders for goods and services, approve reimbursement to individuals, for travel, equipment and all other types of expenditures, and approve journal vouchers and cost transfers. Signature authority has no set dollar threshold and grants total fiscal responsibility to an individual other than the PI. Principal investigators should designate this authority only to staff that are capable of sound fiscal management and have knowledge of administrative policies and procedures. Designees must be an employee of either SDSU or SDSU Research Foundation. Exceptions must be requested in writing and approved by the Director of SRA.
2. Additional Authorization (One-Up Signature) Policy
For most expenditures through SDSU Research Foundation, the SR administrator serves as the one-up authority except in specific circumstances defined under the hosting policy or when programmatic nexus is not easily determined. In those cases, one-up authorization would follow the academic chain (i.e. department chair or dean.) The primary purpose of a one-up authorization is to ensure that the programmatic purpose of the expenditure has been validated by other than the authorized signer on the fund. This is particularly appropriate and prudent when the authorized signer - of whatever rank - is submitting a request for reimbursement to himself/herself. Note: One-up authorization is up the administrative reporting line. One-up authorization cannot be another authorized signer on the fund. For a faculty member or project staff person, it would be the department chair, unless the dean signs. For a department chair, it will be the dean. For a dean, it will be the office of the provost. SDSU Research Foundation will not maintain a list of these administrative levels within each division, college or department. Project directors and principal investigators are charged with ensuring that the appropriate authorizations are obtained, as indicated below:
- Any activity that appears to predominantly benefit the individual or the individual's relatives must be approved (by signature) by the one-up administrative level of the project director/principal investigator submitting the requisition/purchase order/request for reimbursement.
- Any expense submitted in excess of one-year after the date the expense was incurred will require one-up authorization. All expenses should be submitted for reimbursement or payment in a timely manner; typically, within 30 days of incurring the expense.
- Any single hosting event that exceeds $1,000 must be approved (in writing) by the one-up administrative level of the project director/principal investigator submitting the requisition/purchase order/request for reimbursement. If the dean is the project director, the limit is $3,000. Events exceeding $3,000 will require a one-up authorization from the provost's office or applicable vice president's office.
- All Campus and Community Relations funds expended require approval from SDSU Business Affairs.
- When SDSU Research Foundation believes that the documentation requires more detail and/or explanation in order to meet audit requirements, e.g., an unclear nexus between the activity and the stated benefit to the university, paperwork may be returned for more information and/or one-up authorization. The decision to do so is within the authority of the SDSU Research Foundation Sponsored Research Administration department. If deemed unallowable or not timely, the expense will be deemed the responsibility of the individual who incurred the cost.
3. Criteria for Determining the Allowability of Expenditures
SR administrators are required to apply certain standards to expenditures charged to monies generated by sponsored or restricted funds awarded through grants, contracts, cooperative agreements and other agreements (grants or contracts). Federal OMB Circular A-21 contains the cost principles for educational institutions. Individual award documents may also contain substantive guidelines for determining approval of expenditures, i.e., special terms and conditions applicable to a specific project fund. Expenditure activity must be consistent with sponsor guidelines, San Diego State University's academic philosophies and institutional objectives, as well as SDSU Research Foundation's overall policies and procedures. Further, expenses must be necessary to the program, must be submitted in a timely manner, and be supported by appropriate documentation as defined further in this section. In order for a proposed expenditure on a grant or contract to be approved by SDSU Research Foundation, the cost must be allowable, allocable, and reasonable under OMB Circular A-21 cost principles:
- Allowability: The cost must be reasonable and must be given consistent treatment through application of generally accepted accounting principles appropriate to the circumstances. The costs must conform to any limitations or exclusions set forth in the sponsored agreement or in the Federal Cost Principles (OMB Circular A-21).
- Allocability: Once allowability criteria are met, the cost is evaluated for allocability. This means the cost has been incurred solely to support or advance the work of the sponsored agreement and it is consistent with the scope of work contained in the award document. An expenditure is considered allocable if it is made on behalf of or in support of, the expressed purpose of the project and is therefore assignable to that project. If costs are to be split among sponsored agreements, they must be in proportions that can be approximated through use of reasonable measures. Costs to a particular sponsored agreement may not be shifted to other sponsored agreements in order to meet deficiencies caused by overruns or other funds considerations to avoid restrictions or other reasons of convenience.
- Reasonableness: Finally, a cost is evaluated for reasonableness. A cost may be considered reasonable if the nature of the goods or services reflect the action that a prudent person would have taken under the circumstances prevailing at the time the decision to incur the cost was made. Consideration might include whether or not the cost is of a type generally recognized as necessary for the performance of the agreement and/or if there are restraints or requirements imposed by arm's-length bargaining. The reasonableness criterion requires that those committing funds from SDSU Research Foundation funds apply common business sense.
SR administrators also review all payment documents and requests for reimbursement with the following principles in mind:
- Consistency: Transactions must be treated in a consistent manner. Policies and procedures have been established to address similar types of transactions in a routine manner.
- Timely Processing of Payment Documents: All requests for reimbursements, personnel appointments and reimbursement for payments to vendors should be submitted within 90 days of their origination. SDSU Research Foundation is subject to Federal guidelines that require grantee institutions to demonstrate sound business practices in the management of sponsored funds. The majority of vendors require payment of their invoice within 30 days of the date of invoice.
OMB Circular A-21 further states that all financial commitments incurred through the last day of the grant budget period must be processed for payment within the following 90 days. Expenditures submitted after that 90-day window of time may be deemed unallowable. The PI and project staff are responsible for submitting all payment documents in a timely manner to their assigned SR administrator. Administrators may request additional justification for payment documents submitted outside of the 90-day window, and additional management review may be required. - Justification: There must be sufficient justification showing the expenditure supports the project's goals and adheres to sponsor and SDSU Research Foundation guidelines.
- Documentation: Sufficient documentation to support the transaction, such as an itemized, dated receipt, must be included. The documentation should be sufficient to stand alone when reviewed during an audit.
- Certification: The expenditure document must contain the original signature of the PI or other individual who has been authorized to incur expenses on a specific sponsored agreement. (See Section II. F. Signature Authorization.)
4. Cost-Transfers, Payroll Redistribution or Reallocation of Charges
Cost transfers, payroll redistributions and journal vouchers are transactions that move charges from one fund to another or between line items within a fund. Since there are policies and procedures and internal controls in place at SDSU Research Foundation to ensure that costs are accurately recorded, an original transaction should not need to be corrected. However, in certain circumstances, it may be necessary to move a direct charge expense from one fund to another or within a fund to link the cost more appropriately with the benefit it is providing.
In order to limit the need for cost transfers, payroll redistributes and journal vouchers, PIs are encouraged to work with their SR administrator to accurately project expenditures and allocate funds. Monthly budget reports should be used to compare project budgets against expenditures to date and future commitments to determine if overruns will occur. If an overrun is anticipated, the PI should contact his/her SR administrator to prepare a cost projection or budget adjustment.
A cost transfer is a direct charge expense transferred from one fund to another after the charge has been posted in the financial accounting records of SDSU Research Foundation. Cost transfers include redistributions of payroll expenses as well as the transfer via a journal voucher of other direct costs. The Cost Transfer Policy is applicable to all funds that SDSU Research Foundation administers.
Policy and Procedure: All requests for cost transfers or payroll redistributions should be submitted in writing to your SR administrator and contain the following:
- Documentation: In order for a cost transfer or redistribution of payroll to occur, it MUST be supported by written documentation that contains a full explanation and justification for the transfer. The justification should be prepared in such a way that a person outside of SDSU Research Foundation (i.e., an auditor) would be able to understand why the cost transfer is necessary and should address the following questions:
- Why the expense was originally charged to the fund from which it is now being transferred?
- Why should the charge be transferred to the proposed fund? How the expense is appropriate or fit the scope of work of the proposed fund?
- Why is this transfer being requested more than 90 days after the cost was initially charged?
- What action will be taken to eliminate the future need for cost transfers of this type? Is this action being taken?
- Approvals: A cost transfer or payroll redistribution must have the approval signatures of the PI, the SR administrator, and SDSU Research Foundation's manager of Sponsored Research Administration. Cost transfers or payroll redistributions initiated over 120 days after the transaction date must have the approval of the director of sponsored research administration.
- To be acceptable, cost transfers and payroll redistributions must be timely, allocable to proper budget categories, and allowable under applicable sponsor and SDSU Research Foundation policies, properly documented, and approved. All cost transfers and payroll redistributions shall become part of the official project file and subject to audit. Requests for cost transfers or payroll redistributions that lack adequate documentation and/or approval signatures may be denied.
- Unallowable Cost Transfers. The following cost transfer situations are typically considered to be unallowable:
- Cost transfers requested more than 60 days after the end date of a sponsored agreement.
- Transfer of charges from any sponsored agreement that is in an overrun status to another sponsored agreement.
- Transfer of any reimbursed-time transactions or direct salary payments to faculty where the effort report has already been certified. (All adjustments made to faculty payroll must go through the effort reporting system and should be made before the employee's effort certification is signed and received.)
- Journal Vouchers are utilized for a variety of purposes including but not limited to recording transactions for charge backs from SDSU recharge centers, internal transfers of cash between SDSU Research Foundation funds, and corrections to elements of the accounting string associated with a revenue or expenditure transaction, including the Fund, Organization, Account and Program. Please submit requests for Journal Vouchers to your SDSU Research Foundation SR administrator.
5. Specialized Categories of Expenditures
The purpose of this section is to identify costs that require more substantial documentation or that have unique policies or procedures associated with the approval process. Please refer to Section III. Purchasing and Accounts Payable and Section IV. Travel for additional information.
- Hosting Policy
Hospitality expenses may be paid with SDSU Research Foundation funds only when the purchase and use of these items is consistent with the mission and fiduciary responsibilities of SDSU Research Foundation. This policy applies to activities that promote the University/SDSU Research Foundation to the public and the provision of hospitality in connection with official University/SDSU Research Foundation business. Hospitality is defined as the provision of meals or light refreshments, promotional items, gifts, and travel expenses of official guests of the University/SDSU Research Foundation. This policy has been prepared to be in compliance with University policy and is subject to changes if campus policy changes.- Allowable Expenses and Occasions
Hospitality expenses must be directly related to, or associated with, the active conduct of official University/SDSU Research Foundation business. When a University/SDSU Research Foundation employee acts as an official host, the occasion must, in the best judgment of the approving authority, serve a clear University/SDSU Research Foundation business purpose, with no significant personal benefit derived by the official host or other University/SDSU Research Foundation employees. Expenditures should be in line with what a prudent person would consider normal and reasonable.
Hospitality expenses are normally not allowable on grants and contracts (5 ledgers), unless the proposal narrative addresses these activities as an integral part of the program or approval is obtained by the funding entity. However, in certain instances food purchases may be allowed as part of the approved project budget for a sponsored project. An example of allowable food related activity that may be included in a sponsor-approved budget is a professional meeting or workshop that runs for several hours. In this case, a meal may be offered to the participants in order to maintain continuity of the meeting or as an incentive. In addition, some Campus and Community Program (CCP) funds (9 ledgers), Research Support funds (2 ledgers) or The Campanile Foundation (TCF) funds (C ledgers) include hosting as a part of the normal requirements of the project or organization.
When determining whether a hospitality expense is appropriate, the project must evaluate the importance of the event in terms of the costs that will be incurred, the benefits to be derived from such an expense, the availability of funds, and any alternatives that would be equally effective in accomplishing the desired objectives.
Hosting may be allowable in the following circumstances:
Hosting of Non-Campus Groups or Individuals: Food and beverages when hosting non-campus persons - if for the purpose of promoting the campus- When the University/SDSU Research Foundation hosts official guests, including University employees visiting from another work location (the main campus is a single work location), donors, and prospective donors;
- Relationship-building activities with donors and others -Activities other than dining may be used as venues for cultivating donor support or for establishing and building relationships with individuals or corporations, which are of benefit to the University. An example might be golf or sporting events. Documentation must address and support the benefit of the university.
- When the University/SDSU Research Foundation hosts receptions held in connection with conferences, meetings of a learned society or organization, fundraising events, meetings of student organizations and groups, employee recognition or length of service awards or retirement presentations, bereavement acknowledgement, student events such as commencement exercises, and meetings of other university related groups.
- Official campus functions, including retirement receptions and gifts and awards to employees are allowed. Designation of a farewell event as an official campus function requires vice presidential approval or approval of the executive director of SDSU Research Foundation. Official campus functions do not include off-site parties, dinners, or similar events organized by coworkers and friends.
- Hosting is allowed when the University/SDSU Research Foundation is the host or sponsor of meetings of an administrative nature that are directly concerned with the welfare of the University/SDSU Research Foundation and the provision of hospitality is a necessary and integral part of the business meeting and not solely a matter of personal convenience;
- On campus, during normal business hours: Food and non-alcoholic beverages for on-campus meetings during regular work hours are allowable only if the "provision of hospitality is a necessary and integral part of the business meeting" (E.O. 761). Expenditure or reimbursement documentation must provide sufficient explanation of the "necessary and integral" requirement.
- Off campus, during normal business hours: Food and beverages for off-campus meetings attended only by employees of the same work location is an allowable expense only during agendized meetings. (e.g. retreats and strategic planning meetings).
- On or off campus, before or after normal business hours: Food and beverages for meetings taking place before or after work is an allowable expense if the meeting was necessarily scheduled at a time and manner to accommodate availability of multiple attendees. Documentation as to the reason why the meeting had to be scheduled outside of normal working hours is required.
- On or off campus, during lunch period: Requests by employees for reimbursement for business luncheons with colleagues during normal work hours are to exclude the lesser of an amount equivalent to the lunch per diem currently in effect or the cost of the hosting administrator's meal. This exclusion recognizes that the host would have normally incurred a luncheon expense and removes questions as to personal benefit to the official host.
Tobacco Products: Tobacco products are prohibited by campus policy. Such expenditures would be allowed under SDSU Research Foundation policy only if documented for research purposes.
Employee Morale: Judicious use of funds for employee morale is allowable for such activities as bereavement or illness acknowledgements, recognition of length of service or exceptional employee performance, etc. However, employee birthdays, weddings, anniversaries, showers, and other personal celebrations or acknowledgements are not allowed under any circumstances
Vendors: Entertainment of vendors must be carefully executed in order to avoid giving the appearance to other vendors of impaired impartiality. Entertainment of vendors to solicit donor support should be restricted to those situations where (1) the University/SDSU Research Foundation already has, through contract or purchase order, established the business relationship with the vendor; or (2) the University/SDSU Research Foundation does not intend to do contractual business with the vendor. Entertainment of vendors to establish or improve relationships dependent on personal interaction is allowable.
Travel (transportation and lodging): Travel for building relationships with individuals or corporations, including cultivating donor relationships, is permitted. This includes reimbursement of travel expenses of invited University guests.
Community involvement expenses: Allowable activities include memberships or purchases of tables at fund-raising events and minor donations (less than $100) to charitable organizations when made in lieu of flowers as an expression of sympathy
Contributions: Donations or contributions toward not-for-profit organizations whose purposes intersect with or promote the mission of the University are only allowable if approved by the President or his named designee.
Documentation Requirements: Each reimbursement request must have sufficient background and documentation so that an auditor reviewing a specific expenditure understands the relevance of the event or activity to the project or the University. Only those activities that provide adequate justification will pass an audit. The following type of documentation is considered appropriate when submitting requests for reimbursement for a hosting expenditure, regardless of the source of funds used.- A full description of the purpose of the activity that addresses the activity as an integral part of the project and/or fully describes the benefit of the hosting activity. Given that judgment is very often an intangible but nonetheless critical basis for an expenditure (such as employee morale), the individual requesting reimbursement is encouraged to be as specific as reasonably possible when stating the benefit to the campus;
- Date, time and location of the activity and/or a meeting agenda that includes this information;
- Original itemized receipts or invoices are required (establishes audit trail for type of expenditure and number of employees). If itemized receipts cannot be obtained or have been lost, a signed statement to that effect is required. On a selected basis, venues may be called to verify that itemized receipts are not available to customers.
- Credit card receipts are required (establishes that expense was incurred and paid by the employee and not some other individual). Payment in cash, because there is no proof that the individual requesting reimbursement actually was the payer of the expense, is to be on an exception basis only.
- Identification of participants in attendance (i.e., a sign-in sheet for a workshop that lists the names of the individuals attending) and relationship with the University or Foundation.
Note: One-up authorization is up the administrative reporting line. One-up authorization cannot be another authorized signer on the fund. For a faculty member or project staff person, it would be the department chair, unless the dean signs. For a department chair, it will be the dean. For a dean, it will be the office of the provost. SDSU Research Foundation will not maintain a list of these administrative levels within each division, college or department. Project directors and principal investigators are charged with ensuring that the appropriate authorizations are obtained, as indicated below:- Any single hosting event that exceeds $1,000 must be approved (by signature) by the one-up administrative level of the project director/principal investigator submitting the requisition/purchase order/request for reimbursement. If the dean is the project director, the limit is $3,000. Events exceeding $3,000 will require a one-up authorization from the provost's office or applicable vice president's office.
- Hosting activity that appears to predominantly benefit the individual hosting the event or the individual's relatives must be approved (by signature) by the one-up administrative level of the project director/principal investigator submitting the requisition/purchase order/request for reimbursement.
- Other hosting activity where SDSU Research Foundation believes that the documentation requires more detail and/or authorizing explanation in order to meet audit requirements, e.g., an unclear nexus between the activity and the stated benefit to the university, may be returned for more information and/or authorization. The decision to do so is within the authority of the SDSU Research Foundation Sponsored Research Administration department.
- All Campus and Community Relations funds expended require approval from SDSU Business Affairs.
- Check Request Standard Form (Excel Format, 26KB)
- Check Request Expanded Form (Excel Format, 27KB)
- Allowable Expenses and Occasions
- Wireless (Cellular) Telephones, Palm Pilots, PDAs
Due to the increased use of wireless communication tools to conduct SDSU Research Foundation project business, SDSU Research Foundation has implemented the following policy and procedures.
Prior to the purchase of any of these tools, employees are required to complete a Wireless Communication Tools Request form. The completed form should be forwarded to the SR administrator for review to determine if the expense is allowable under sponsor and SDSU Research Foundation guidelines. This type of expense may be considered an allowable cost for a 2 ledger (Research Support Funds), C ledger (Campanile Foundation) or 9 ledger (CCP) fund but may be charged on an exception basis only to 5 ledger (Sponsored Agreement) fund. Prior approval from the SR administrator is required. The Wireless Communications Tools Request form (PDF Format, 36KB) is available. - High Speed Cable/DSL Internet Access
If determined by the project director that there is a work-related need for an employee to have high-speed cable or DSL Internet access at home he/she may submit a request to be reimbursed for the amount that corresponds to the professional use of this service.
Prior approval from the SR administrator is required for this type of expenditure as it may be considered an unallowable cost under sponsor agency or SDSU Research Foundation guidelines. The project director should forward a completed Application for High-Speed Internet Access (Word Format, 34KB) to his/her SR administrator. This form requires a detailed description of the nature of work to be performed using the high-speed internet access and how it pertains to the mission of the department or scope of work for a project. A rationale for the necessity for access outside of regular working hours and away from the office must also be included. The employee and the employee's supervisor must sign the application and send it to the SR administrator.
The SR administrator then submits the signed application form to the SRA director for approval.
Upon receiving the SRA director's approval of the application, the SR administrator returns a copy of the form to the project director, makes a copy to attach to the check request and puts the original in the project file.
The employee can now submit receipts for reimbursement: Employees pay for the installation and monthly billing charges but can get reimbursed the amount that corresponds to the percentage of their professional use for that billing period. The employee uses the SRA Internet Access Check Request form on which he or she certifies the percentages of professional and personal use during the requested billing period. Upon reviewing this form and receipts, the SR administrator approves for payment. - Consultant and Independent Contractor Payments
PIs frequently use consultants to perform specific tasks when specialized skills or expertise is not available internally. In most cases, an Independent Contractor Pre-Selection Checklist (Word Format, 98KB) should be completed.
Before an individual is retained as a consultant or independent contractor, the PI should contact his/her SR administrator for assistance in determining whether an employee/employer relationship exists. The decision to hire an independent contractor is a calculated business risk. If SDSU Research Foundation misclassifies an individual as an independent contractor instead of an employee, it can be liable for excessive fines and penalties. No potential penalties are incurred for paying an independent contractor through the SDSU Research Foundation's payroll system.
A variety of different legal standards are used to determine whether or not an individual is an employee or an independent contractor. The SR administrator, SR management and the director of human resources are available to assist the PI in applying these standards to ensure the individual is paid appropriately. Please note that any consultants that are also CSU employees must be paid through payroll.
Consulting arrangements in excess of $5,000 may require a consultant agreement in addition to the independent contractor form. A consultant agreement is a contract with an individual rather than an organization that contains specific contractual language concerning task oriented time lines, payment methods and cancellation clauses. The agreement also includes a brief scope of work and budget.
The consultant agreement can be initiated any time the principal investigator or the SR administrator determines that tighter controls are required due to the dollar amount of the agreement, the time period of the agreement, or the nature of the work and/or deliverables. Each independent contractor form with a dollar threshold of $5,000 or greater, and/or a specified contract period of greater than 3 months is to be reviewed to determine if a consultant agreement is necessary. See Evaluating Independent Contractor vs. Employee Status section for more information. - Subcontracting and other Sub agreements
A sub agreement is an agreement issued under a larger contract, agreement or grant that authorizes a portion of the research or substantive effort to be performed by another organization. The word subcontract will be used throughout this section to refer to all types of sub agreements including subcontracts, MOU's and other third party agreements. The subcontract document outlines the rights and responsibilities of each party.
Typically at the proposal stage, the PI determines whether they will be collaborating with another institution to complete the proposed scope of work. The SR development office will review the subcontract materials as well as the full proposal before submitting the proposal to the sponsor. SR development will ensure that the subcontracting institution has reviewed and approved their portion of the proposal and has submitted a budget and scope of work along with any required institutional assurances for including into the SDSU Research Foundation proposal. SR development will ensure each institution knows its respective role, the budget is adequate to support the work and someone authorized to sign on behalf of the subcontracting organization has endorsed the subcontract proposal. If a subcontract is named on a final sponsor approved budget, and no other restrictions are listed on the award, the subcontract is considered approved. Note: Some agencies require additional sponsor review and approval of the final subcontract document even if the collaborating institution is named in the proposal. If there is a need to subcontract a portion of the work but no subcontract was indicated in the proposal, the SR administrator must typically secure sponsor approval before a subcontract can be finalized. Prior sponsor approval protects the interests of SDSU Research Foundation and the university. Without prior approval, the sponsor has no responsibility to allow subcontract costs.
In order to issue a subcontract, the project must follow a process of solicitation, proposal and award. A request for proposal (RFP) will be developed by the PI and the SR administrator using the scope of work provided by the PI. The goal is to receive a minimum of three responses to the solicitation. Upon selection of an institution, SDSU Research Foundation will negotiate, prepare the subcontract agreement, and finalize the arrangements.- Overview of the Subcontract Process:
- If a subcontract is named on the final sponsor approved budget, and no other restrictions are listed on the award, then the subcontract is considered approved. If not, prior sponsor approval is typically required before a subcontract can be finalized. A letter of intent may be issued to the subcontractor, if necessary, pending approval of the subcontract and/or receipt of the prime grant award.
- The principal investigator should contact his/her SR administrator to start the process of issuing a subcontract.
- The SR administrator is responsible for all correspondence with the subcontractor to ensure that compliance issues are met and that reporting and invoicing is in accordance with the agreement. The SR administrator monitors the subcontract in much the same manner as the original award. This monitoring includes requests by the subcontractor for budget adjustments, supplements and no cost extensions. The SR administrator also handles problems regarding the invoicing process.
- The SR administrator will forward a Disclosure of Financial Interest form for the PI to complete and return. The SR administrator may also request the name of the subcontractor PI and an administrative contact if this information was not included in the proposal document.
- The SR administrator will determine if the proposed subcontractor institution is currently an approved subcontractor with current financial statements and certificates of insurance on file with SDSU Research Foundation. If needed, the SR administrator will request these items from the subcontractor institution. SDSU Research Foundation's Finance and Accounting Manager must approve the financial statements of the proposed subcontractor before a contract will be issued.
- The Finance and Accounting Manager will identify high-risk sub awardees and may impose additional restrictions on documentation procedures. The SRA Director also assesses risk. Factors considered include A-133 audit comments, size of institution, type of institution, amount of award, cost sharing requirements, adequacy of financial systems, scope of work, and previous history with subcontractor.
- The SR administrator will also contact the PI to obtain/verify budget information, scope of work, reports or deliverables that will be required from the subcontractor. The SR administrator will prepare the subcontract agreement and forward it to the subcontractor for review and approval.
- If the subcontractor does not request modifications to the agreement, the partially executed agreement is forwarded to the SRA Director for review and approval. If the subcontracting institution requests revisions to the subcontract, the SR administrator will work with them on the request for modification.
- Once the fully executed agreement is in place, the SR administrator encumbers the funds and provides a copy of the fully executed agreement to the subcontractor. The subcontractor submits invoices monthly directly to SDSU Research Foundation's Accounts Payable Department. This department forwards the invoice to the PI for review and signature approval. The PI forwards the signed payment form to the SR administrator for final signature. The PI should notify the SR administrator of any concerns with the progress or deliverables associated with the subcontract. Approval of the invoices may be held at the PI's request pending satisfactory performance. The SR administrator will carefully review the subcontract's invoice/financial report as part of the approval process. The payment authorization form is forwarded to A/P for processing the payment.
- Subrecipient Monitoring:
SDSU Research Foundation is responsible for every aspect of the performance of the project, including the subcontract portion. SDSU Research Foundation's obligation to the sponsor agency does not change if the subcontractor has unsatisfactory progress or defaults. Therefore, if any problems arise in the performance or spending of the subcontractor, appropriate action will be taken. SDSU Research Foundation's PI is responsible for acting as the technical monitor of the subcontract and oversees the technical performance of the subcontractor to ensure satisfactory performance and submission of required technical reports and deliverables.
- Overview of the Subcontract Process: