What is the difference between the Office of Research and Sponsored Projects Accounting?
The Office of Research is the central, pre-award administrative department reporting to the Senior Vice Chancellor for Research. The Office of Research is responsible for the central, pre-award administration and management of sponsored projects at the University. Responsibilities include providing funding source information, guidance on proposal writing, final pre-submission proposal review, negotiation, approval, processing, management and administration of notices of awards and serves as the University Signatory Authority and Authorized Institutional Official with respect to sponsored projects.
Why are these two offices separate?
The Sponsored Projects Accounting is the central, post-award accounting department reporting to the Office of the Controller, which in turn reports to the Office of the Chief Financial Officer at the University of Pittsburgh. Sponsored Projects Accounting is responsible for the central, post-award accounting, administration and management of sponsored projects at the University. Responsibilities include timely and accurate post-award accounting, financial reporting, invoicing, accounts receivable management and administration of sponsored project funds from account activation to account closing.
The University of Pittsburgh is a very large institution, with a large, diverse volume of third-party sponsored project support. The Office of Research serves as the central, pre-award, administrative contracts department reporting to the Senior Vice Chancellor for Research. Sponsored Projects Accounting serves as the central, post-award accounting department reporting to the Chief Financial Officer. To ensure that a proper system of internal administrative and accounting controls are maintained, the existence of two separate offices with distinct responsibilities represents a proper segregation of duties and organizational reporting for a University our size.
The Office of Research and the Sponsored Projects Accounting department work closely together to effectively administer, manage and account for sponsored projects at the University.
Who do I contact for matters related to pre-award, central activities?
As mentioned above, the Office of Research handles all pre-award, central administrative activities. Central, pre-award activities include serving as Authorized Institutional Official, Signatory Authority for sponsored projects, grant vs. gift determinations, proposal review, approval and submission, sponsored project negotiations, subcontract negotiations and pre-award sponsored projects compliance.
Who do I contact for matters related to post-award, central activities?
The website http://www.pitt.edu/~offres/ lists the names of staff members in the About Us section that work with various departments in the University. The staff name, phone number and e-mail address is available.
As mentioned above, Sponsored Projects Accounting handles all post-award, central accounting and administrative activities. Central, post-award activities include serving as financial/fiscal officer for sponsored projects, new account creation for sponsored projects in the general ledger, gift vs. grant determinations, accounting for sponsored projects amendments and modifications, invoicing and letter of credit responsibilities, cash application, accounts receivable for sponsored projects, the majority of financial reporting, sponsored projects closing, post-award sponsored project compliance.
Who do I contact for documentation on charges I can’t recognize on a sponsored project?
The Sponsored Projects Accounting website at http://www.cfo.pitt.edu/rca/ra_assignments.html lists the Sponsored Projects Accounting staff directory and the University departments they are assignEd to. The staff directory provides the e-mail addresses and telephone numbers of these individuals. Responsible Sponsored Projects Accountants are also listed on each, individual sponsored project RPAR 001 Report.
Who do I contact if a sponsor requires a Certificate of Insurance for a pre-award sponsored project application or early in the post-award sponsored project administration process?
Charges to sponsored projects should be justified and documented by the preparer of the accounting entry. To determine the preparer of an entry in the general ledger, a query on the batch name should be done in Oracle (PRISM). Contact the person listed in the “Prepared By” field for the batch. That person will be able to provide the detailed information.
Certificates of Insurance are the responsibility of the Department Administrator, and can be obtained by searching on the University’s Risk Management website under the Chief Financial Officer’s website. They can be requested utilizing the Certificate Request Form under the subject of Certificates of Insurance.
Project Account Numbers
How do I get an early account number for a sponsored project?
Establishing an early account number is an internal accounting control which is integral to a proper system of internal controls over sponsored projects as it allows for proper and timely sponsored project financial management. To request an early sponsored project account number, the Department needs to initiate the Early Account Request Form (EAR) through the Office of Research. The early account number form is on the Office of Research website along with instructions on what is required to obtain an early account number.
How long does it take to receive a project number in the PRISM Oracle Financial system?
Finally, it must be noted that the requesting department assumes all financial risk with respect to costs incurred and recorded to an early account in the event the notice of award is never received by the University.
Once a sponsored project notice of award has been approved by the Office of Research and all appropriate internal documents have been accumulated and forwarded to Sponsored Projects Accounting, a project number will be assigned within 72 hours or less.
Does the sponsored project account numbering system have any relevance or is the numbering system just sequential?
A copy of the Activation Report (RPAR105) is delivered via PRISM to the designated administrator at the department the day after the activation occurs. The Activation Report must be reviewed by the Department Administrator upon receipt to ensure the correctness and accuracy of the sponsored project activation. Any errors, omissions or oversights must be immediately brought to the attention of the Sponsored Projects Accountant activating the project account.
A sponsored project numbering system has been developed using the first one or two digits of the six-digit sponsored project account number to designate a funding source:
- NSF 01xxxx
- Dept. of Education 07xxxx
- DHHS Agencies on Letter of Credit 1xxxxx
- DHHS Agencies not on Letter of Credit, Other federal agencies and federal pass-through agencies 40xxxx
- State & Local Govt. 60xxxx
- Foundations and Companies 70xxxx
Why do I get a new project number for each project year for certain sponsored projects?
The last four digits are sequential as new project numbers are assigned.
Some sponsors restrict the University’s authority to carryover an unobligated balance (unspent funds) from one grant year to the next and therefore require advance approval of any carry over.
Per the NIH Grants Policy Statement carryover of unobligated balances requires prior approval on awards for center grants (P50, P60, P30, and other awards), cooperative agreements (U awards), Kirschstein-NRSA institutional research training grants (T awards), non-Fast Track Phase I SBIR and STTR awards (R43 and R41 awards), and clinical trials (regardless of activity code), unless otherwise noted in the NOA. In addition, other awards may be excluded from carryover authority. You must refer to the terms in the NOA.
Regardless of any direction we receive from our pass-through agencies, our University must follow the terms and conditions of the award being passed-through to us.Since carry over must be approved in advance, related accounts can never extend more than one year in length, unless a no-cost-extension is awarded to the prime award.
Regardless of award type, it is University procedure to establish new accounts annually in PRISM for BOTH cost reimbursable and fixed price awards. This is the standard procedure followed by the University for awards with restrictions on carry over for both federal and non-federal sponsors. Examples of non-federal sponsors with carryover restrictions includes American Heart Association, Cystic Fibrosis Foundation, Howard Hughes Medical Institute, Breast Cancer Research Foundation, as well as others.
Payments on Sponsored Projects
Who are cash payments on sponsored projects to be made payable to, and where are cash payments to be sent for sponsored projects?
University of Pittsburgh
All cash payments are to be made to the University of Pittsburgh. All cost reimbursable and installment invoice payments for sponsored projects are to be mailed to the Sponsored Projects Accounting bank lockbox at:
500 Ross Street 154-0455
Pittsburgh, PA 15262-0001
What do I do with a check received in my department for a sponsored project?
On sponsored projects where departments invoice sponsors and receive checks directly from sponsors such as clinical trial awards, it is acceptable for the checks to be mailed first to the departments issuing the invoices to ensure payments are received, then the checks can be forwarded to Sponsored Projects Accounting for deposit.
Any check received by a department for a sponsored project should be hand carried to the Sponsored Projects Accounting office on the 31st floor of the Cathedral of Learning so that funds can be sent to the bank the same day. The department must provide the 6 digit sponsored project account number that identifies the sponsored project to which the payment applies.
How do I know if an agency has paid all invoices on a cost reimbursable agreement?
Checks should never be retained by a department for an extended period of time as this increases the possibility of a check being lost, stolen or a check becoming stale dated and being rejected by the bank.
The RPAR001 – Summary of Activities – Level II, for each sponsored project, provides the following accounting information:
- Subcode 1200 – Current Accounts and Notes Receivable – Gross provides the cumulative, total amount that the sponsor has been invoiced to date on the sponsored project
- Subcode 1202 – Current Accounts and Notes Receivable – Payments provides the cumulative, total amount that the sponsor has paid to date on the sponsored project
The net of these two numbers represents the outstanding balance the sponsor owes the University related to the sponsored project.
Why does our department sometimes receive a copy of a collection letter to an agency?
Although primary responsibility for University accounts receivable and collections on sponsored projects resides with Sponsored Projects Accounting, departmental monitoring and awareness of the current status of outstanding accounts receivable of their sponsored projects accounts also represents an important internal control of the University.
The University’s sponsored projects accounting system, known as the Research Proposal Accounting system (RPA), was programmed to generate accounts receivable delinquency letters for invoices reaching a certain threshold of delinquency. Sponsored Projects Accounting copies the PI on all delinquency letters to keep them informed and to serve as an early warning system that the sponsored project may be in financial regression.
On occasion, PIs can be called upon to notify colleagues at sponsoring agencies to assist in getting sponsored projects back-on-track financially.
What is cost sharing?
When is it appropriate to cost share?
Cost Sharing or matching is the funding or costs contributed or allocated to a sponsored project not borne by the sponsor. Cost sharing can be required by law, regulation or administrative decision of a sponsor. Cost sharing requirements vary by sponsor and between grants from the same sponsor. Funding agencies believe that cost sharing reflects a grantee’s interest in or commitment to the sponsored research or, the potential benefits derived by the grantee beyond the reimbursable costs on the grant.
Most sponsors of the University have no cost sharing requirements. Therefore, cost sharing should only occur if it is required by the sponsor, and the PI, Dean or Director of the performing Department has the funding to meet the actual cost sharing requirement. All costs of cost sharing must be borne by the performing Departments. Costs incurred on sponsored projects other than the project having the cost sharing requirement cannot be used to meet the cost sharing requirements on the subject project. There is no central reserve set aside to meet sponsored project cost sharing requirements.
How does a department account for cost sharing?
It is inappropriate to volunteer cost sharing if it is not required by a sponsor as voluntary cost sharing increase the overall cost of sponsored projects to the University in a number of different ways. Guidance provided by sponsors indicates that volunteering cost sharing does not increase the chances of a proposed project being funded by that sponsor
Cost sharing must be accounted for in a Departmental account in either the Entity 02 or the Entity 04 Ledgers. The Department must be prepared to account for and report the cost sharing to the sponsor when required.
Sponsored Project Compliance Issues
Why can’t departments continue charging a prior year project while waiting for a subsequent year project number to be activated?
Sponsoring agency regulations, guidelines and notice of award requirements stipulate that all sponsored projects have award periods that begin and end at specified dates and typically include a 90 day post-performance period after a project ends for costs identifiable to the project to be recorded in the University’s financial system. Our sponsored project ledger must reconcile to costs invoiced and reported on the sponsored project for the applicable period of performance.
Why does the write-off of a sponsored project overdraft have to be charged to subcode 8000?
Costs beyond this stipulated period of performance representing costs in a subsequent project year cannot be charged to a prior-year project number to maintain the integrity of the costs invoiced and reported in prior periods. Accordingly, University Departments must request an Early Account Number from the Office of Research in a timely manner, or fund the charges on an Entity 02 or 04 account while waiting for a new sponsored project number to be assigned. This is why the negotiation of a new NOA in a timely manner is of paramount importance.
The write-off of a sponsored project overdraft must be charged to subcode 8000 for two reasons:
Reason No. 1: Sponsored project overdrafts cannot be transferred to any other sponsored project account.
Reason No. 2: The University must include sponsored project write-offs in the sponsored projects cost allocation bases for F&A Cost Rate Proposal preparation purposes and must exclude these write-offs from the sponsored projects cost allocation pools.
Why do sponsored project cost transfers have to be done within 90 days after the cost appears on University level reports?
Subcode 8000 cannot be transferred via journal entry in the PRISM financial system and is the mechanism we utilize to identify overdrafts for development of the University’s F&A Cost Rate. Accordingly, this is a key internal accounting control of the University with respect to sponsored projects that must be strictly adhered to. Do not transfer costs that represent overdrafts due to over spending prior to the end of the sponsored project or without utilizing subcode 8000.
The University is required to follow federal and other sponsoring agency regulations and requirements with respect to sponsored projects accounting and administrative control and compliance.
These sponsor regulations and requirements, as well as a proper system of internal controls over sponsored projects require the University to monitor sponsored projects costs continuously and record any sponsored project cost transfers timely. Failure to process cost transfers in a timely manner may be indicative of a lack of adequate internal control and monitoring over the financial administration and accounting for sponsored awards.
Also reference the University’s Cost Transfers Financial Guideline at:
Who do I contact for guidance on Cost Transfers over 90 days?
Finally, reference the Sponsored Projects Accounting website at:
Why isn’t the department’s Department Manager or other departmental “shadow system” considered the official accounting record of the University?
Reference the previously listed policies and for salary cost transfers, contact the Office of Financial Compliance for Research on the Office of the Controller’s website.
Why does Sponsored Projects Accounting return residual funds on a sponsored project?
Federal and other sponsoring agency regulations and requirements with respect to sponsored projects accounting and administrative control and compliance requires that the University have an official financial system that meets the requirements for recording and reporting expenditures in a compliant and consistent manner. The Oracle financial system (PRISM) meets this requirement and is therefore considered the only official financial record of the University.
Sponsored Projects Accounting follows the terms of the NOA and sponsoring agency regulations, guidelines and requirements and University Policies when dispositioning residual funds on sponsored projects. Accordingly, Department Administrators and PIs need to do the same when making such requests.
Reference Residual Funds On Sponsored Projects in the Account Closing Section of this website.
I am submitting a proposal to a direct or pass-through federal agency, and that agency requires the University of Pittsburgh to have accounting and or purchasing (procurement) systems that have been approved by a government agency. Does Pitt have such approved accounting and purchasing systems?
The University of Pittsburgh is an Institute of Higher Education. The University of Pittsburgh is also a Federal Department of Health and Human Services (DHHS) cognizant University.
As such, we are subject to Federal regulatory requirements set forth by OMB Uniform Guidance. Our University’s accounting system is compliant with the Uniform Guidance.
The aforementioned OMB Uniform Guidance collectively has no requirements for our University to have or obtain an “approved accounting or purchasing system” by any Federal agency including the Department of Defense. Our University does over $300M of Federal sponsored project activity annually without a federally approved accounting or purchasing system.
Receipt by our University of a single or multiple Department of Defense or other Federal agency awards subject to Federal Acquisition Regulations (FAR) does not supersede our Federal regulatory requirements or DHHS cognizance and accordingly does not require our University to obtain a federally approved accounting or purchasing system delineated by the FAR.
University Negotiated Rates
How do I know what the current F&A (indirect cost) rates are?
How do I know what the current fringe benefit rates are?
University F&A rates are negotiated and approved by the federal government on a periodic basis. Federally approved indirect cost rates are communicated annually to the University sponsored projects community utilizing the University’s 3D list (Deans, Directors and Department Heads) via the University Read Green email and online platforms. They may also be found on the Cost Accounting website http://www.bc.pitt.edu/rca/ca_rateinfo.html
Do I automatically get the new federal F&A rate on federal and federal pass-through sponsored awards?
University fringe benefit rates are negotiated and approved by the federal government on an annual basis. Federally approved fringe benefit rates are communicated annually to the University sponsored projects community utilizing the University’s 3D list (Deans, Directors and Department Heads) via the University Read Green email and online platforms. The fringe benefit rates are available on the same website as listed above for current indirect cost rates.
Not unless they are negotiated into the sponsored project NOA.
The University negotiates F&A rates with the federal government on a periodic, multi-year basis. The rate-type represented by these negotiated rates is known as “predetermined”. Predetermined federal F&A rates cannot change over the life of the award. Life of the award means each competitive segment. However, the University negotiates rate agreements that can contain different F&A rates over the span of the Rate Agreement that should be applied over the life of a sponsored project. In other words, once the F&A rates are negotiated and incorporated into a sponsored project agreement, the rates cannot change but they can be different.
Where does a department go for information on regulations from the federal government on sponsored project activities?
What regulations apply to my job?
The Sponsored Projects Accounting website have links to pertinent federal and other agency regulations and requirements. The web address is http://cfo.pitt.edu/rca/ra_srg.html. These regulations and requirements can also be found with a simple internet search.
All federal and non-federal agency specific regulations and requirements, as well as all sponsored projects University Policies and Procedures are applicable to every person at the University working with sponsored projects. We are all responsible for self-educating ourselves in this regard and taking ownership of our responsibilities.
University Processes and Procedures
Where does a department obtain information on University policies and procedures related to sponsored project activities?
The University website has a Policies, Procedures and Handbooks website that posts this information. The web address is: http://www.cfo.pitt.edu/policies/.
How does a department obtain access into the PRISM Oracle financial system?
What is the difference between subcodes 8120 and 8130?
Access to PRISM can be obtained by accessing the following website: http://prism.pitt.edu/ and following the instructions.
Subcode 8120 – Budget Reserves/Restricted Budget represents budget that is restricted from use. Sponsored project budgets may be restricted for a number of reasons. Sponsors may indicate funds are awarded but restricted from use for a number of reasons, including but not limited to pending IRB or IACUC approval. Such restrictions are typically referenced within the Notice of Award. Additionally, a department may restrict budget on a fixed price clinical trial agreement to represent anticipated but not yet earned budget, such as in the case of patient enrollments not yet met.
Which office needs to approve transfers for Research and Development Fund accounts, and where do I send the Budget Modification Request for transfers?
Subcode 8130 Budget Unallocated – Sponsored Projects Only represents unallocated budget. This subcode is used by Sponsored Projects Accounting as a final budget adjustment to reduce the budget to match the final expenses reported to the sponsor. This subcode should not be used by a performing department, either when preparing a budget to establish a Sponsored Project or when preparing a budget modification. Sponsored projects have budgets that are negotiated and fully allocated to cost categories upon initiation.
Transfers between Research and Development Funds accounts, require prior approval from the SVC for Research. Departments should obtain approval from the SVC’s Office and the BMR should be submitted to Sponsored Projects Accounting for processing.
What are departmental responsibilities for closing out a project?
How do I know when a project I am responsible for will be closing?
Departmental responsibilities for closing out a project are documented in the Sponsored Project Account Lifecycle section of this website.
Why do I only have 45 days after the period of performance expires to prepare a Closing Memorandum for a sponsored project that has ended?
Ninety days before the end of a sponsored project period of performance, a system generated notice is included with the RPAR001 – Summary of Activities – Level II report that notifies the Department Administrator that the project will end in 90 days. In addition, Department Administrators and PIs are responsible for monitoring sponsored project end dates so that appropriate closing procedures can be initiated timely.
Federal and other sponsoring agencies regulations and requirements often times require the University to operationally and financially close a sponsored project within 90 days after the period of performance of the sponsored project expiration. This includes the submission of the final sponsored project financial report.
What do I do when a no cost extension is requested, but not yet received for a sponsored project whose end date is approaching?
Accordingly, Department Administrators are allotted half of the closing period after the sponsored project has expired to complete their closing responsibilities, and submit the required information to Sponsored Projects Accounting so that the final financial report can be completed and submitted timely. (If the final financial report is due in 30 days, the department would have 15 days to submit the Closing Memorandum, etc.) Sponsored Projects Accounting takes the other half of the closing period in order to manage its workload.
It is critical that Departments request no cost extensions well before the end date of a project – preferably 60 days prior to closing. An agency’s written approval of a no-cost extension from someone of authority at a sponsor should be submitted to the Office of Research and to Sponsored Projects Accounting immediately upon receipt. Verbal authorizations are not acceptable.
Who prepares and approves the Closing Memorandum?
If an approval has not been received in Sponsored Projects Accounting before the required final financial reporting due date, Sponsored Projects Accounting will financially report on the sponsored project to the sponsor in final in order to meet the requirements of the NOA.
The performing Department prepares the Closing Memorandum. The Closing Memorandum is typically prepared by the Department Administrator or other individual with direct, first-hand knowledge of where the sponsored project is expected to close financially, with support from the PI.
Approval of the Closing Memorandum is a business decision of the performing Department. Departments can make their own determinations as to who they require to approve financial Closing Memorandums. Sponsored Projects Accounting expects only that the closing be accurate and approved by an individual of authority with direct, first-hand knowledge of where the sponsored project is expected to financially close.
Who prepares the following account closing documents?
- Final Invoice
- Responsibility of Sponsored Projects Accounting
- Final Financial Report
- Responsibility of Sponsored Projects Accounting
- Final Intellectual Property Report
- Responsibility of the Performing Department
- Final Property Report
- Responsibility of Sponsored Projects Accounting
- Final Contractor’s Release
- Responsibility of Sponsored Projects Accounting
- Final Contractor’s Assignment of Refunds, Rebates and Credits
- Responsibility of Sponsored Projects Accounting
What type of financial audits occur at the University?
Who pays for the sponsored project audits on Commonwealth awards? How much is the audit fee?
Reference the section of this website on Audit Support.
What should I do in the event that I am contacted regarding a financial audit or external investigation of a sponsored project or other aspect of University activity?
Audit fees should be budgeted for and charged to the sponsored project account to which the sponsored project audit applies. Please contact the Sponsored Projects Operations Manager to obtain the most current audit fee amount to be budgeted.
Please contact Sponsored Projects Accounting if you are contacted regarding an audit of a sponsored project that has not already been coordinated through a central, administrative office of the University.
Please contact the Campus Police if you are contacted regarding an investigation of a sponsored project that has not already been coordinated through a central, administrative office of the University. Campus Police have detectives/investigators on staff that will serve as the liaison on the investigation. Don’t work directly with an external investigator unless authorized by the AVC of Public Safety and Emergency Management, Campus Police or the Office of General Counsel.
How long should I retain all accounting and administrative documents/images that support sponsored project accounts?
The OMB Uniform Guidance require a minimum 3 year retention period from the date of submission of the final financial report. In consideration of the potential for sponsored program audit, tax audit and requirements of state escheat laws, the University adopts a conservative retention period of 7 years regardless of cost of record keeping as the cost of not retaining these records for these oversight authorities and related embarrassment is deemed to be far greater.
If there are any active litigation, claims, or audit matters related to a sponsored project that extend beyond the expiration of the 3-year retention period, then records must be retained until all litigation, claims, or audit findings involving the records related to the sponsored project have been resolved and final action taken.
Where do I obtain information related to University effort reporting?
Reference the University’s Policy on Effort Reporting at: http://cfo.pitt.edu/policies/documents/policy11-01-07web.pdf
Also reference the Controller’s Office, Financial Compliance for Research web site at: http://www.cfo.pitt.edu/fcr/index.php