Purpose:
To establish guidelines for financial management on sponsored awards which are consistent with federal, state, city and private grantor regulations. This policy is intended to comply with the requirements from the Office of Management and Budget Uniform Guidance (UG) as well as requirements from our federal/non-federal sponsors.
Scope:
This policy is applicable to faculty and staff who are involved in administering sponsored awards.
Effective Date:
August 24, 2016
Responsibility:
The interpretation and administration of this policy shall be the responsibility of the Grants and Contracts Accounting Office in consultation with the Associate Vice President and Controller.
Policy:
This policy applies to all sponsored awards at Teachers College (TC). The Grants and Contracts Accounting Office (GCA) is committed to maintaining a financial management system that provides accurate, current, and full disclosure of all grant accounting and management activities. GCA’s financial management system ensures compliance with laws, regulations, and provisions of awarding agencies. GCA, as a recipient of grant funds, is responsible for compliance with all applicable federal and state laws, regulations, and provisions of awarded grants and contracts. To ensure that the College meets this responsibility, GCA must remain familiar and comply with directives of the Federal Office of Management and Budget (OMB).
Standards for Financial Management System
In accordance with OMB Uniform Guidance section 200.302 Financial Management, GCA maintains a financial management system that provides the following:
- TC’s financial management system, including records documenting compliance with federal statues, regulations, and the terms and conditions of the federal/non-federal award, is sufficient to permit the preparation of reports required by general and program-specific terms and conditions, and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the award, including those in the Uniform Guidance 200.450 Lobbying.
- TC’s financial management system provides appropriate record management, including retention of records (see TC Document Retention Policy), as well as honoring requests for transfer of records, methods of collection, transmission and storage of information, access to records, and the restriction on public access to records (pursuant to Uniform Guidance sections 200.334, 200.335, 200.336, and 200.337 respectively).
- TC’s financial management system identifies, in its accounts, all federal/non-federal awards received and expended and the federal/non-federal programs under which they were received. Federal program and federal award identification includes, as applicable, the Catalog of Federal Domestic Assistance number (CFDA), federal award identification number and year, name of the federal agency, and name of the pass-through entity, if any. Accordingly, GCA assigns the following Banner index numbers to each individual awards: 511xxx to 515xxx = Federal funding; 516xxx = Federal pass-through to TC; 520xxx = State funding; 530xxx = City funding; 54xxxx = Foundation and Corporation funding. TC maintains centralized grant award files and also maintains a centralized grants database.
- TC’s financial management system includes an accurate, current, and complete disclosure of the financial results of each federal award or program that allows for preparation of reports in accordance with the reporting requirements set forth in the Uniform Guidance 200.327 (Financial Reporting) and 200.328 (Monitoring) and reporting program performance. TC uses and maintains records via the accrual method of accounting. TC, when serving as a prime recipient (pass-through) entity, does not require its subrecipients to establish an accrual accounting system, but allows the subrecipient to develop accrual data for its reports on the basis of an analysis of the documentation at hand.
- TC maintains records that identify the source and application of funds for federally-funded activities. These records contain information pertaining to federal awards, authorizations, obligations, unobligated balances, assets, expenditures, and income and interest; supported by source documentation.
- TC maintains effective control over, and accountability for, all funds, property, and other assets. Records for movable assets above the College’s capitalization threshold of $3,000 are managed by the Business Services Office’s fixed asset tracking system. TC further safeguards all assets and assures that assets are used solely for the authorized purpose.
- TC maintains comparison of expenditures with budget amounts for each federal award via monthly budget variance reports which are generated by the Controller’s Office for on-line access and reviewed by GCA and the respective Principal Investigators (PIs) and/or Department Administrators (DA).
- TC maintains written procedures to implement the requirements of Uniform Guidance section 200.305 Payment (Please see Policy under TC Cash Management).
- TC maintains written procedures for determining the allowability of costs in accordance with Subpart E-Cost Principles of the Uniform Guidance and the terms and conditions of the award. Please see the TC policy under Sponsored Agreements-Accounting for Allowable and Unallowable Costs.
Teachers College maintains a robust system of internal controls consisting of policies, procedures and internal systems. These functions all work together, providing a series of controls, checks, and balances to ensure compliance with Uniform Guidance section 200.303 Internal controls by:
- Managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the award.
- Complying with federal statues, regulations, and terms and conditions of the award.
- Evaluating and monitoring TC’s compliance with federal statues, regulations, and terms and conditions of the award.
- Taking prompt action when instances of noncompliance are identified.
- Taking reasonable measures to safeguard protected personally identifiable information and any other information deemed sensitive by the funding source.
Responsible Office: Controller
Last Updated: August 2016