i. Signature Authorization
ii. Electronic Signatures/Approvals
iii. Additional Authorization (One-Up Authorizaton) Policy
iv. Criteria for Determining the Allowability of Expenditures
v. Cost-Transfers, Payroll Redistribution or Reallocation of Charges
vi. Specialized Categories of Expenditures

i. Signature Authorization

The PI is responsible for complying with the financial and administrative policies and procedures applicable to each fund including sponsored programs awards, campus and community programs, research support funds, and other SDSU Research Foundation fund types under their funding portfolio. The PI has exclusive authority to incur expenses against the award and 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, to initiate and authorize expenditures including purchase orders for goods and services, to approve reimbursement to individuals for travel, equipment, and all other types of expenditures, and to 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. Importantly, the PI should designate this authority only to individuals 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 be approved by the director of SRA.

ii. Electronic Signatures/Approvals

SDSU Research Foundation utilizes information systems that support electronic transactions, including electronic approvals (e-authorization). Unique accounts (user id and password) are created for individual employees and are for the use of that individual only and must NOT be shared. Use of on-line user ids and passwords in SDSU Research Foundation systems is the equivalent of a wet ink signature on paper. Individuals shall be liable for all activities on their assigned accounts.

iii. Additional Authorization (One-Up Authorization) Policy

The SRA grant specialist serves as the one-up approval authority except in specific circumstances defined under the hosting policy and when relevancy to a program is not easily determined. In those cases, one-up authorization would follow the academic chain* The primary purpose of a one-up authorization is to ensure that the programmatic purpose of the expenditure has been validated by someone other than the authorized signer on the fund. This is particularly appropriate and prudent when an authorized signer is submitting a request for reimbursement of their own expenses.

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 will 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. The project director and PI are charged with ensuring that the appropriate authorizations are obtained in the following circumstances:

• Any activity that appears to predominantly benefit the individual or the individual’s relatives.
• Any expense submitted more than one year after the date the expense was incurred. All expenses should be submitted for reimbursement or payment in a timely manner; typically, within 30 days of incurring the expense.
• Expenditures and occasions requiring one-up authorizations must be in accordance with SDSU Research Foundation’s hosting policy (see II.G. Expenditure Processing, 6.a.).
• When SDSU Research Foundation determines that the documentation requires more detail and/or explanation to meet audit requirements, (e.g., an unclear connection between the activity and the stated benefit to the university), requests 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 SRA department. If found to be unallowable or not timely, the expense will be the responsibility of the individual who incurred the cost.

iv. Criteria for Determining the Allowability of Expenditures

SRA grant specialist is 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). Awards issued on or after December 26, 2014, are subject to the Office of Management and Budget (OMB) “Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (2 CFR, Part 200)”. These federal regulations contain the cost principles for the administration of federal awards. Individual award documents may also contain substantive guidelines for determining approval of expenditures, such as special terms and conditions or restrictions applicable to a specific project fund.

Expenditure activity must be consistent with sponsor agency 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, submitted in a timely manner, and supported by appropriate documentation as defined further in this section.

IFor a proposed expenditure on a grant or contract to be approved by SDSU Research Foundation, the cost must be allowable, allocable, and reasonable under the federal cost principles outlined in 2 CFR Part 200 Subpart E- Cost Principals (Uniform Guidance) as applicable:

1. Allowable Costs. The cost must be necessary and reasonable for the performance of the award and must be given consistent treatment through the 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 2 CFR Part 200 (Uniform Guidance). Costs must also be incurred during the approved budget period for the award being charged.
2. Allocable Costs. An expenditure is considered allocable to a specific award if it is made on behalf of, or in support of, the expressed purpose of the project and is therefore assignable to that project. This means the cost has been incurred specifically to support or advance the work of the sponsored agreement and it is consistent with the scope of work contained in the award document. If costs are to be split among sponsored agreements, they must be in proportions that can be approximated using reasonable measures. Costs to a particular sponsored agreement may not be shifted to other sponsored agreements to meet deficiencies caused by overruns, other funds requirements to avoid restrictions, or other reasons of convenience.
3. Reasonable Costs. 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 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 factors such as: sound business practices; arm’s-length bargaining; Federal, state, local and other laws and regulations; and the terms and conditions of the award. The reasonableness criterion requires that those spending from SDSU Research Foundation funds apply common business sense.
   
   
   SRA grant specialist also review all payment documents and requests for reimbursement with the following principles in mind:


4. Consistency: Transactions must be treated in a consistent manner. SDSU Research Foundation policies have been designed to address similar types of transactions in a consistent manner.
5. 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. Most vendors require payment within 30 days of the date of invoice.
   
   2CFR Part 200.344 OMB Uniform Guidance further states that all financial commitments incurred through the last day of the grant budget period must be finalized to allow for the submission of final financial reports no later than 120 calendar days after the end date of the award (or an earlier date as required by the sponsor agency). The PI and project staff are responsible for submitting all final payment documents to their assigned SRA grant specialist within the 90 days following the budget period to be processed for payment. Expenditures submitted after that 90-day window of time may be deemed unallowable. SRA grant specialist may request additional justification for payment documents submitted outside of the 90-day window, and additional management review may be required.
6. Justification: There must be sufficient justification showing the expenditure supports the project’s goals and adheres to sponsor and SDSU Research Foundation guidelines.
7. Documentation: Sufficient documentation to support the transaction, such as an itemized, dated receipt, must be included. The documentation should contain adequate detail to stand alone when reviewed during an audit.
8. Certification: The expenditure document must be approved by the PI or other individual who has been authorized to incur expenses on a specific sponsored agreement. (See Section II. G. Signature Authorization.)

v. 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.

To limit the need for cost transfers, payroll redistributions and journal vouchers, the PI is encouraged to work with their SRA grant specialist to accurately forecast 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 their SRA grant specialist to prepare a cost projection or budget adjustment.

A cost transfer is a direct charge expense transferred from one fund/award 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 transfer of expenditures between funds awarded under the same grant is not considered a cost transfer. An example of this type of transfer is the correction of expenditures that posted to a prior budget period under the same award, i.e., moving an expenditure from the “A” year to the “B” year of an award. The Cost Transfer Policy is applicable to all funds that SDSU Research Foundation administers.

Cost Transfer Policy and Procedure: All requests for cost transfers or payroll redistributions should be submitted in writing to the assigned SRA grant specialist and contain the following:

• Documentation: All requests for cost transfers or payroll redistributions 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 was the expense originally charged to the fund from which it is now being transferred?
  • Why should the charge be transferred to the proposed fund? How does the expense fit the scope of work/purpose of the proposed fund?
  • If applicable, 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 of the PI or other authorized signer for the affected funds, the SRA grant specialist, the SRA manager, and an associate director of SRA. Cost transfers or payroll redistributions initiated over 60 days after the fund end date may also require the additional approval of the director of SRA.
• Acceptability. Cost transfers and payroll redistributions must be timely, allocable to proper budget categories, 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 authorized approvals 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 or after the final invoice or final financial report has been submitted.
  • 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.)
  Extenuating circumstances will be reviewed on a case-by-case basis and must be clearly and substantially documented.
• Journal Vouchers 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. Submit requests for journal vouchers to the SRA grant specialist.

vi. 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. Refer to Section III. (Purchasing), Section IV. (Accounts Payable), and Section V. (Travel), and Section VI. Human Resources for additional information.

1. Hospitality Policy
   Hospitality expenses may be paid with SDSU Research Foundation funds when such expenses are necessary, appropriate to the occasion, reasonable in amount and serve a purpose connected to 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 and authorizes appropriate SDSU Research Foundation funds to be used for such purposes. This policy is written to be consistent with university and CSU policies and procedures.
   
   Hospitality expenses may not be charged to grants and contracts (5 ledger funds) unless the proposal narrative addresses these activities as an integral part of the program or approval is obtained by the funding entity.
   
   The complete hospitality policy is available at: https://foundation.sdsu.edu/pdf/sra_hosting_policy.pdf
2. Computing Devices
   Computing devices and accessories (or “peripherals”) for printing, transmitting and receiving or storing electronic information costing under $5,000/unit may be considered as allowable costs that can be charged to a project if:
   
   
   • they are essential and allocable to the project in that they are necessary to acquire, store, analyze, process and publish data and other information electronically and;
   • the project does not have reasonable access to other devices or equipment that can achieve the same purpose; devices may not be purchased for reasons of convenience or preference.
   
   The PI is encouraged to specifically budget for computing devices and include a detailed explanation of the essential nature of the items at the proposal phase of the award. If not specifically budgeted, the PI is responsible for providing this information to their SRA grant specialist prior to the cost being incurred to ensure the purchase meets federal agency and award specific requirements.
   
   NOTE:Items costing more than $5,000/unit are considered equipment and subject to policies and procedures specific to equipment purchases.
3. Cell Phones & Wireless Devices
   Federal regulations state that telephone costs are typically unallowable as a direct cost on a grant; however, direct charging of these costs may be appropriate if the use of a cell phone is essential and allocable to the project, the item is specifically budgeted for and approved by the sponsor agency. Contact the SRA grant specialist with questions regarding allowability and award specific terms regarding this type of cost.
   
   The project should submit a Request to Direct Charge Cell Phone Expenditures to a Sponsored Project form to the SRA grant specialist prior to incurring costs. Sponsor approval may be required if the costs were not specifically budgeted for and approved by the funding agency at the proposal stage.
   
   Due to the unique characteristics of each sponsored project, the director of SRA will review and approve requests to direct charge cell phones or other wireless communication devices on a case-by-case basis.
4. Administrative and Clerical Salaries
   Federal regulations (2 CFR 200.413) state that the salaries of administrative and clerical staff should normally be treated as indirect (F&A) costs on sponsored agreements. However, direct charging of these costs may be appropriate only if all the following conditions are met:
   
   • Administrative or clerical salaries are integral (i.e. essential, vital or fundamental) to the project or activity
   • Individuals involved can be specifically identified with the project or activity
   • Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and
   • The costs are not recovered as indirect (F&A) costs.
   
   To facilitate sponsor approval, the PI is encouraged to specifically budget for these costs and include a justification statement that addresses the criteria under items 1 and 2 in the proposal document. If new or additional (over 25% of the amount previously approved) administrative or clerical support is needed during the life of the award, sponsor approval must be obtained in writing before any costs are incurred. The SRA grant specialist will work with the PI to obtain prior approval from the sponsor agency.
5. Participant Support Costs
   Participant support costs include stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences or training projects. These costs are not routinely allowed on research projects but can be charged if the project includes an education or outreach component and the sponsor agency approves such costs.
   
   Federal regulations (2 CFR 200.456) state that participant support costs are allowable with the prior approval of the sponsor agency. Participant support costs should be explicitly listed in the proposal budget and budget justification. After an award has been made, requests to add new participant support costs line items to the budget or make changes to existing line items require prior written approval by the funding agency. The PI should work with their SRA grant specialist to obtain prior approval.


6. Consultant and Independent Contractor Payments
   
   No work may be performed until approval is confirmed.
   
   Consultants or Independent Contractors are often engaged to perform specific tasks when specialized skills or expertise is not available internally. There are complex Federal and State laws that are used to determine whether an individual should be treated as an employee or an independent contractor. SDSU Research Foundation Human Resources will make the final determination regarding independent contractor status or employee/employer relationship.
   
   If the proposed consultant does not qualify as an independent contractor, the individual must be hired as an SDSU Research Foundation employee to perform the work. Individuals who are currently employed by SDSU or SDSU Research Foundation are not considered independent contractors (See VI. Human Resources, A.10 Evaluating Independent Contractor vs. Employee Status)
   
   The PI should contact their SRA grant specialist for assistance with obtaining approval to engage an independent contractor. The SRA grant specialist will work with the PI to compile the information needed including an Independent Contractor Pre-Selection Checklist, scope of services, payment, location of services and other business-related information. The SRA grant specialist will submit the information to Human Resources for determination of independent contractor or employee status.
   
   Some consulting arrangements may require a consultant agreement in addition to the independent contractor form. Consulting arrangements more than $5,000 and/or a specified contract period of greater than three months may require consultant agreement. A consulting agreement may also be required any time the PI or the SRA grant specialist determines that tighter controls are required due to the dollar amount of the agreement, the period of the agreement, or the nature of the work and/or deliverables.
7. Subagreement Procedures
   A subagreement is an agreement issued to an external organization under a prime award received by SDSU Research Foundation. The subagreement authorizes a portion of the project activity to be performed by another organization. The word “subagreement” will be used throughout this section to refer to all types of subagreements including collaborative agreements, subagreements, subawards, subcontracts, memorandums of agreement, memorandums of understanding and other third-party agreements. The subagreement document outlines the rights and responsibilities of each party.
   
   At the proposal stage, the PI determines whether they will be collaborating with another institution to complete the proposed scope of work. The SRD office will review the subagreement materials as well as the full proposal before submitting the proposal to the sponsor. SRD will also ensure that the subrecipient institution has reviewed and approved its portion of the proposal and has submitted a budget and scope of work along with any required institutional assurances to be included in the SDSU Research Foundation proposal. SRD will work with the subrecipient institution to obtain necessary approval for collaboration with the SDSU PI, ensure the budget is adequate to support the scope of work, and verify the authorized institution official has endorsed the subagreement proposal. If a subrecipient is named on a final sponsor-approved budget and no other restrictions are included in the award document, the subrecipient is considered approved.
   
   Note: Some agencies require additional sponsor review and approval of the final subagreement document, even if the subrecipient institution is named in the proposal. If there is a need to issue a subagreement for a portion of the work, but no subrecipient was indicated in the proposal, the SRA grant specialist must secure sponsor approval before a subagreement can be finalized. Prior sponsor approval protects the interests of SDSU Research Foundation and the university. Without prior sponsor approval, the sponsor has no responsibility to reimburse subagreement costs.
   
   To issue a subagreement for the procurement of goods or services (as opposed to work to be performed), the project must follow a process of solicitation, selection and award. The PI will work with SRA to develop a request for proposal (RFP) 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 a subrecipient, SDSU Research Foundation will negotiate, prepare the subagreement, and finalize the arrangements.
8. Overview of the Subagreement Process:
   
   
   1. The PI contacts their SRCC analyst to initiate the issuing of a subagreement.
   2. The SRCC analyst works with the PI during the preparation of the subagreement. The SRCC analyst is primarily responsible for corresponding with the subrecipient to ensure that compliance issues are met. The SRCC analyst will confer with the PI to ensure that reporting and invoicing are in accordance with the prime award.
   3. The SRCC analyst forwards a Disclosure of Financial Interest form for the PI to complete and return. The SRCC analyst requests the name of the subrecipient PI and an administrative contact if this information was not included in the proposal document.
   4. The SRCC analyst determines if the proposed subrecipient institution is currently approved with current financial statements and certificates of insurance on file with SDSU Research Foundation. If needed, the SRCC analyst requests these items from the subrecipient institution.
   5. SDSU Research Foundation's finance and accounting audit manager reviews and approves subrecipients based on review of the recipient’s Single audit or financials before a subagreement is issued.
   6. The audit manager identifies high-risk sub-awardees and may impose additional restrictions on documentation requirements. Risk assessment includes review of financial statements and Single Audit findings, type and size of the organization, amount of the subagreement and adequacy of the organization’s financial systems.
   7. The SRCC director also assesses risk in completing a restricted party screening (review to exclude entities that are debarred, suspended or otherwise restricted from receiving funding) at the initiation and prior to fully executing the subagreement. Additional review is performed to determine whether additional restrictions should be imposed including subrecipient’s knowledge of sponsored programs administration requirements, potential compliance issues, cost-sharing requirements, and previous history with subrecipient. If needed, the SRCC director also collaborates with the SRA director to determine if any additional areas should be addressed in the subagreement.
   8. The SRCC analyst contacts the PI to obtain/verify budget information, scope of work, reports or deliverables that are required from the subrecipient. The SRCC analyst works with the SRCC director to prepare the subagreement, encumber funds and forwards to the PI for approval. Upon approval, the subagreement is then transmitted to the subrecipient for review and approval.
   9. If the subrecipient does not request modifications, the subagreement is partially executed and returned to the SRCC director to fully execute. If the subrecipient institution requests revisions, the SRCC analyst works with the SRCC director and the subrecipient on the requested modification. Negotiations take place until all parties agree on the terms and conditions of the subagreement.
   10. Once the fully executed subagreement is in place, the SRCC analyst provides a copy of the fully executed subagreement to the subrecipient and the SRCC technician files the document in the electronic filing system.
   
   
   The SRA grant specialist is responsible for subrecipient monitoring and serves as the point of contact for any problems associated with the subagreement. Subrecipient monitoring may include requests for budget adjustments, supplemental funding (carryover), and no-cost extensions. The subrecipient submits invoices as frequently as monthly directly to SDSU Research Foundation's accounts payable department. This department forwards the invoice to the PI for review and approval. The PI approval includes a certification that the work is progressing satisfactorily and all technical reports and/or deliverables due have been received. The PI should notify the SRA grant specialist of any concerns with the progress or deliverables associated with the subagreement. Approval of the invoices may be held at the PI request pending satisfactory performance. After the PI has approved the invoice, the SRA grant specialist will review and authorize the subrecipient’s invoice/financial report for payment. Unless the subrecipient has been designated as a “high-risk sub awardee” supporting documentation for the subrecipient’s invoice/financial report is generally not required.


9. Subrecipient Monitoring:
   SDSU Research Foundation is ultimately responsible for every compliance aspect of the project, including the subagreement portion. SDSU Research Foundation’s obligation to the sponsor agency does not change if the subrecipient has unsatisfactory progress or defaults.
   
   The PI is responsible for acting as the technical monitor of the subagreement and are responsible for oversight of the performance of the subrecipient to ensure satisfactory completion of the scope of work. This includes:
   
   
   • Monitoring the subrecipient’s technical and programmatic activities as they relate to the subagreement.
   • Reviewing subrecipient's technical/performance reports as required.
   • Verifying subrecipient has completed the scope of work in both a timely and satisfactory manner.
   • Reviewing and approving invoices submitted by the subrecipient. This includes reviewing expenditures to ensure they are appropriate for the work being performed and in accordance with the terms and conditions of the subagreement.
   • Maintaining regular contact with the subrecipient.
   • Notifying the SR grant specialist of any concerns with the subrecipient's performance or spending.
   • Working with SR Administration and the subrecipient to resolve any issues identified.
   
   SR Administration is responsible for subrecipient monitoring in accordance with federal requirements, award specific terms and conditions and research foundation policies and procedures. This includes:
   
   
   • Reviewing subrecipient invoices to ensure costs are allowable, allocable and reasonable, and are appropriate for the approved budget and the terms and conditions of the subagreement.
   • Ensuring that subrecipient invoices are approved by the PI or his/her designee and submitted in a timely manner.
   • Requesting additional information or source documentation from the subrecipient if invoices contain costs that are questionable or insufficiently detailed.
   • Working with PIs to resolve any concerns reported. Resolution of significant concerns may involve the PI, SR Administration, SR Contracting and Compliance and the subrecipient. Actions taken by SRA will be based on the individual situation and may include performing a desk audit, requesting and approving a subrecipient corrective action plan, additional monitoring of subrecipient's progress and follow-up action for non-compliance.


10. Scholarship/Fellowship Payments to Individuals
    Scholarship/Fellowship disbursements may only be issued to individuals who are not required to perform any past, present, or future services in exchange for the payment. Individuals participating in activities warranting the payment of scholarship or fellowship funds will have been selected for participation in conjunction with the eligibility requirements associated with the project award guidelines. The disbursement of funds to an individual may cover books, equipment, fees, living expenses, supplies and/or tuition required for courses or instruction or participation in project activities.
    
    The receipt of scholarship/fellowship funds can affect a student’s eligibility for financial aid. The SDSU Office of Financial Aid and Scholarships reviews payments made to students by SDSU Research Foundation and uses this information to determine the allowable amount of financial aid for each affected student.
    
    Individuals receiving payment under the above circumstances will complete the Notice to Recipients of Scholarships and Fellowships form. If the individual receiving payment has applied for or has been awarded financial aid, approval from the SDSU Office if Financial Aid is required prior to any payments being issued from SDSU Research Foundation.
    
    The form is located at: https://foundation.sdsu.edu/doc/ap_fa_notice_schol_fellow.docx
    
    The Internal Revenue Service does not require SDSU Research Foundation to report taxable fellowship and scholarship income to either the individual or the IRS. It is entirely the responsibility of the U.S. citizen or resident alien to report any taxable income on their tax return. If the recipient has any questions, it is recommended that they engage a tax professional.

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