Office of Sponsored Programs & Research Compliance

image 475x230Managing Your Award

The principle investigator is the primary person responsible for the proper management of an externally sponsored project. S/he must conduct the work as outlined by the sponsor approved scope of work (original or revised) and within the authorized budget. Any changes to these areas should be coordinated through the Grant Officer to the sponsor for review. UNCW has a broad range of authorities delegated by sponsors that can handle most modifications; however, there are certain sponsors and/or actions which must receive specific sponsor approvals.

When authorizing expenditures to be made to a grant/contract, the PI is certifying those expenses are appropriate, necessary, and directly related to the approved scope of work relevant to that project. It is critical that the PI understand this responsibility. Charges made to a grant/contract not directly related to the scope are not allowable and cannot be charged. Not carefully reviewing expenditures can result in increased audit risk to the entire university and disallowed expenditures that have to be paid by the university. To help alleviate some of the headaches associated with managing your grant, SPARC has developed a PI Checklist

  • PI Reference Handbook (Under Development)
  • E-Print

Fiscal Management

As a general rule, contract and grant funds must be expended in accordance with university policies, state regulations, and sponsor requirements. A principal investigator is expected to manage her/his grant funds in a manner consistent with these principles and exercise sound fiscal management. All expenditures made against a grant fund should be reasonable, allowable under the above guidance, and allocable to that specific project. The expectation is each transaction would pass the "reasonable person" test, as well as the "front page" test. Please see our legal terms and definitions for more information.

There are several resources available to PI's to assist in managing your grant/contract. SPARC provides support in managing the budget, liaison between PI and sponsor, reviewing and assisting with personnel actions, planning, and assisting in issue resolution. The SPARC provides staff support to the IRB and IACUC and should be the contact point for submission of protocols and any questions. SPARC issues sub-agreements in cooperation with the PI and negotiates and accepts awards on behalf of the university. PI's have "real time" access to their grant funds to monitor balances and expenditures.

Purchasing Services can assist in identifying potential vendors, determining the necessity for and managing the open bid process if required, process requests for purchasing cards, and provide information on state acquisition regulations. They are the signatory authority for the university on purchased services.

Accounting also provides guidance on the allowability of expenditures under state regulations, travel requirements, payroll/withholding issues, petty cash/subject payments, and other non-purchase order issues.

Human Resources can assist in determining the classification and pay scale of grant employees, benefits applicable to a specific class of employee, and provides approval for hiring actions. All employment actions must be consistent with university and state personnel policies.

Allowable Charges

In order to be allowable on a grant/contract, all charges must, first and foremost, be reasonable, allocable to the specific project, and allowable under sponsor, university, and state regulations. The university expects and requires budget authorities to exercise the highest standards of ethical and responsibility in the conduct of grants/contracts.

Charges to grants/contracts are reviewed for compliance with university and state rules, including the need to seek bids for large transactions or provide justification for sole source acquisition. Travel follows university rules unless the sponsor has issued more restrictive ones. Projects are permitted to have purchasing cards.

SPARC reviews all expenditures for personnel, foreign travel, contracted services, independent contractors, and reviews equipment purchases. Sub agreements are issued through SPARC with the input of the PI. Invoices against sub-awards are received in SPARC, approved by the PI, then processed.

Federal projects are held to OMB Circular A-21 standards of allowable transactions. If there will be charges which are normally unallowable but if this project has special reasons to acquire these (i.e. alcohol for research) and the items are specifically identified in the proposal and/or have specific sponsor approval, they will be allowed.

Attention Please!! The Non-Allowable Purchases List has been updated! The following items are now on the list and purchases will be audited for these items beginning September 17, 2014.

APPLE Apps. (Downloads/Uploads)

Computer/PCs, Laptops, Google Glass, Servers, Notebooks, all Tablets (Including Microsoft Surface and iPads), Netbooks, Programming, Maintenance, Repair and Service, Network/Information Service.

Guidance for allowable charges for both grants and contracts from the Federal Government:
OMB Circular A-21

For Federal Contracts and purchase orders the below Federal Acquisition Regulation (FAR) apply concerning Contracts with Educational Institutions and FAR Contract Price/Cost determination

UNCW Business Affairs policies

Reporting Requirements

Program/project reports as required by the sponsor are to be submitted by the PI. A copy is forwarded to SPARC for the grant file. It is the responsibility of the PI to ensure these are submitted within the specified deadlines. Often, a sponsor will only reimburse the University for expenses incurred after the receipt of the specified reports; therefore, it is a matter of concern when reports are not submitted as required. Fiscal reports are prepared by UNCW's Billing Department with significant input of SPARC. Property reports are also submitted by SPARC as required by the sponsor.