Policies & Procedures


Section: C&G
Part: PRO
Statement No.: 4.1
Date: 02/04/08
University of North Carolina - General Administration
Administrative Policies and Procedures Manual
Title: Compliance Responsibilities

Sponsored Programs and the Division of Finance will coordinate certain compliance and pre-audit functions with project directors and work units as follows:

    a. Develop and deliver training for administrative staff supporting externally funded activities

    b. Ensure consistent and compliant budgeting of direct costs vs. facilities and administrative (F & A) costs (pre-award phase).

    c. Ensure consistent and compliant charging of direct vs. F & A costs (pre-audit function).

    d. Obtain and retain appropriate written justification as needed for costs that meet certain "unlike circumstances." Provide these justifications, when requested, to internal and external auditors.

    e. Conduct pre-audit reviews of all charges to sponsored awards to ensure that expenditures and subsequent adjustments to expenditures are reasonable, allowable, allocable, timely and non-personal and applied consistently in like circumstances. See Statements No. 4.4 for specific information about allowable and unallowable costs.

    f. Obtain adequate justification for prior approval requests to determine the impact of the request on the technical aspects of the project as well as its reasonableness in terms of costs. Prior approval requirements for each sponsored project can be determined by reviewing the following documents:

      i. Fund Authority Sheet

      ii. Award document and any regulations cited therein

    g. Document all cost sharing in an acceptable format and submit in a timely manner when required. Maintenance of supporting documentation is required. See Statement No. 4.8 for specific information about cost sharing.

    h. Adjustments to expenditures are performed in a timely manner.

    i. Review subcontractor costs for reasonableness and compliance with prior approval and cost sharing requirements before processing invoices for payment. See Statements No. 4.4 for specific information about allowable and unallowable costs and Statement No. 4.8 for specific information about cost sharing. See item f above for determining prior approval requirements.

    j. Perform monthly reviews of charges to sponsored awards (Ledger 3 accounts) appearing on FRS expenditure reports to ensure that all charges were pre-audited. Determine that no unallowable or unrelated costs were charged to the project in error.

    k. Monitor the timely submissions all technical reports.

    l. Obtain and retain appropriate support documentation for financial transactions. This includes cost-sharing documentation as well.