GEORGETOWN UNIVERSITY DIVISION OF FINANCIAL AFFAIRS
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1 Policy # FA GEORGETOWN UNIVERSITY DIVISION OF FINANCIAL AFFAIRS Sponsored Projects Financial Reporting and Financial Closeouts Responsible Department Financial Affairs Effective Date July 1, 2008 Responsible Official Director, Sponsored Projects Financial Operations Last Revision New PURPOSE: In general, sponsors require a financial accounting of the funds expended in support of a project and in accordance with a sponsor approved budget. The timing and detail for such reports is specified in the award document. Interim, final financial reports and invoices provide the sponsor with evidence of good stewardship of the funding. Failure to report in the manner and on the timeline prescribed by the sponsor may call into question the ability of the PI to manage the project and/or the financial controls of the University STATEMENT: This policy seeks to promote compliance with federal, state, and other sponsor requirements related to sponsored projects financial reporting (OMB Circular A-110 C.52 and D.71). The policy also outlines the responsibilities of the Principal Investigator (PI) or designee, cost center manager, campus financial officers and the Sponsored Accounting Office (SAO) who together are responsible for the timely and accurate preparation and submission of invoices, interim and final reports, collection of all accounts receivable and submission of other sponsored requirements like the final invoices or final financial report, technical and progress report, property/equipment inventory and patent disclosures required under each sponsored project agreement. The University will complete the financial award closeout process at the point of the submission of the final financial report or invoice to disallow further charging against the expired sponsored project and will retain all reports in compliance with the sponsor s and the University s record retention policy. A sponsored project must be properly closed out after it expires to ensure that expenditures are allowable, encumbrances are liquidated, payments have been received, reports have been submitted, the budget agrees with expenditures which agrees with the financial status report. No additional charges can be recorded, and Center Status Report (CSR) generation is cancelled. In the event that a revision to the final report is required within fifteen months following the termination of an award, the cost center(s) will be re-activated upon approval of the Director of Sponsored Projects Financial Operations. Georgetown University shall submit financial reports to the sponsors of research and other scholarly activity that: Accurately reflect the use of sponsored funds as recorded in the financial records of the University; and Are in compliance with the sponsor s terms and conditions.
2 Achieving compliance with this policy is a responsibility shared by Principal Investigators (PI), departmental business offices and Sponsored Accounting Office (SAO). The principal investigator and/or designee must ensure that, prior to financial reporting, all expenses are allowable and allocable to the project and that any required adjustments to expenses are posted in compliance with accounting, reporting and close-out policies and procedures. SAO has the authority to request and, in the absence of timely resolution, to post journal entries to fund cost sharing or to remove unallowable costs or other disallowances. SAO will issue financial reports based upon the general ledger activity at the close of an interim and/or final budget period, consistent with established financial reporting, and account closeout procedures APPLICABILITY: This policy applies to all faculty and staff working directly on sponsored projects; therefore, this policy is to be followed by all principal investigators, departmental administrators, Sponsored Accounting, Office of Sponsored Programs (OSP), and the Office of Sponsored Research for the Georgetown University Medical Center (OSR) ROLES AND RESPONSIBILITIES: Principal Investigator (or designee) Reviews financial reports with their department business office (Cost Center Manager) to determine that financial records accurately reflect the use of sponsor funds. Ensures expenditures are in compliance with the terms and conditions of the sponsored award and University policy. Cost Center Manager Reviews draft report award accounts for potential unallowable costs, overdrafts and transfers to a non-sponsored award. Provides documentation to supporting the mapping of University General Ledger expenditure types to sponsor-requested budget categories. Provides information to support timely interim and final financial reporting. Finalizes charges with internal service providers and provides new charging instructions for ongoing expenses. With the PI, prepares request for no-cost-extension or carry forward request to sponsor and submits them thru OSP or OSR with copy to SAO not less than 15 days prior to the budget end date. Assists in resolving collection issues. Clears all custom commitments and all outstanding Procurement commitments generally no less than 30 days prior to the filing of the final financial report. Retains financial records according to the Records Retention policy.
3 Campus Finance Offices Ensures that PI s and Cost Center Managers perform their duties in a timely and accurate manner. Sponsored Accounting Office Prepares draft financial reports from the University s financial system. Notifies PI and Department Administrator when award end date is within 90 and 30 days. Reviews awards for unallowable costs, overdrafts, and remaining balances. Reviews facilities and administrative charges. Prepares and approves the interim, final financial report or invoice and submits to sponsor. Notifies departments of the date the final financial report or invoice was submitted to the sponsor to facilitate and comply with the University s record retention policy. Closes the project cost centers once all financial obligations have been satisfied. Tracks outstanding receivables, sends out past-due notices, and communicates progress with the academic unit. Adjusts funding in Georgetown s financial systems to match final reported costs. Coordinates financial audits of sponsored projects by federal or external auditors. Facilitates the settlement of uncollectible issues. Maintains financial records according to records retention policy ENFORCEMENT and ACCOUNTABILITY: The policy is enforced by the campuses Chief Financial Officers and Internal Audit. Additional reviews may be conducted by the University s financial auditors, A-133 auditors, or agency specific auditors. Each campus Chief Financial Officer shall report annually to the Senior Vice President, CFO and Treasurer on efforts undertaken by the CFO to ensure this policy s implementation All employees who have financial accountabilities should attend the prerequisite operational training courses through Training and Organizational Development. Classes are listed at: Sponsored Accounting Closeout Actions SAO will inform departments 90 and 30 days prior to the project end-date of impending closeouts. SAO will review the award file to determine if the cost center to be closed is connected to other RX cost centers. If so, each file should be reviewed to determine if it is OK to proceed with the close out of one cost center. SAO will reconcile the final Financial Status Report (FSR) and/or invoice to the Cost Center Status Report (CSR) and also confirm that all accounts receivable cost centers are zero.
4 SAO is to confirm that no open commitments are outstanding. Open commitments other than subcontracts (SAO will close) are to be closed by the department through the Purchasing Office. SAO will confirm in consultation with departments total expenditures and account remaining balances. SAO will prepare and post necessary journals to reclass or remove expenditures or balances from account if not resolved by department within 60 days of expiration. SAO will reduce the award amount to the reported amount on both the FSR and CSR. SAO will inactivate the cost center (no charges can post to expense accounts) when FSR and CSR are balanced ADMINISTRATION AND IMPLEMENTATION: Financial Reporting Interim and final financial reports are prepared and submitted generally by SAO and are based upon the general ledger (CSR), the University official accounting record. The interim and final financial reports must be submitted in the format prescribed by the terms of the award and within the due date. When allowed by terms of agreement the Director of Sponsored Projects Financial Operations will determine if revised report will be submitted on a case by case basis. Material revisions in the sponsor s favor will be submitted. Invoicing and Accounts Receivable Interim and final invoices or vouchers generally are prepared and submitted by SAO according to the terms and conditions outlined in the agreement. Appropriate steps are put in place by SAO to track and collect outstanding accounts receivable. Non-Financial Reports Non-financial reports are basically required during the final closeout of sponsored programs and include such reports as: Progress/Technical Reports - programmatic or technical reports submitted by the PI in accordance with due dates as specified in the award document. Invention/Patent Reports - prepared and submitted by PI in consultation with The Office of Technology Licensing and SAO. Property/Equipment Inventory - prepared and submitted by PI or designee in consultation with SAO when required. Final Award Closeout SAO will prepare and issue final financial report after the sponsored program expires based upon the general ledger activity reflected on the CSR at the date of award expiration. No additional charges may be obligated after the award expires. The sponsored project account will be reconciled to ensure that expenditure, revenue, invoicing and cash received are equal and in balance immediately following the submission of the final financial report. Adjustments will be made to bring the account into balance and the sponsored project account will be
5 closed. Sponsored project ledger accounts will remain open after the reconciliation process if there is an outstanding account receivable or cash issue and will be promptly closed and inactivated once issue is resolved. Record Retention Financial and non-financial reports and other important information will be retained in accordance with the sponsor s and the University s Record Retention Policies RESOURCES: Appendix I: Definitions Appendix II: Federal Requirements OMB Circular A-110 ( NIH Grants Policy Statement ( APPROVAL: Director, Sponsored Projects Financial Operations REVIEW CYCLE: At least annually by Director, Sponsored Projects Financial Operations or more often if the Office of Management and Budget changes requirements.
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