Policies

• Cost Sharing Policy
• Cost Transfer Policy
• Direct Charging Policy
• Effort Reporting Policy
• NIH Salary Cap Policy
• Sponsored Travel Policy

Guidance for Managing Award Expenses

• Equipment Purchases and Upgrades
• Cost Sharing Guidance
• Facilities and Administrative Costs
• NIH Childcare Allowance
• Participant Support Costs
• Sponsored Cost Allocation Methodology
• Summer Salary and Effort Reporting
• Publication Costs

Review your award budget in Workday at the outset of the project and immediately notify Sponsored Projects if changes are required. Review of ongoing expenditures should occur at least monthly to ensure proper allocation of funds in accordance with the approved budget and budget justification.

The Post-Award team manages the cash-related activities of Brown’s sponsored projects. The goal is to maintain appropriate levels of cash flow for sponsored projects while ensuring financial compliance with federal regulations, sponsor requirements and University policies.

Post-Award staff provide the following cash management services to researchers at Brown:

• Process Letter-of-Credit (LOC) cash draws and web-based invoicing for federal awards
• Prepare and file the quarterly Federal Financial Report (FFR) for the LOC awards, and perform funding, cash and expenditure reconciliations
• Process installment or cost reimbursement invoices for nonfederal or federal pass-through grants and contracts and act as the point of contact for billing inquiries
• Process receipts of sponsor payments and ensure they are credited to the correct award and invoice.
• Track sponsored project receivables and initiate collection communication
• Reconcile sponsored project receivables and follow up on unbillable issues

The Post-Award team is responsible for the timely collection of accounts receivable with assistance from the departments (e.g., a payment may be 90 days overdue because a deliverable has not been submitted by the department); however, the department is ultimately responsible for any receivables that cannot be collected from the sponsor.

All purchases incurred within the last 90 days of a project period should be reviewed to ensure the item or service was received during the project period and determine how the item or service provided benefit during the project period, given that it was purchased close to the applicable end date.

Equipment and supply purchases near the end of an award period of performance are considered extremely high risk for disallowance and are subject to additional scrutiny. As a reminder, all sponsored project records are maintained for a minimum of three years after submission of a final report and may be subject to external audit and agency review. A clear and reasonable project specific evaluation of the benefit provided should accompany the transaction. 

Generally, the purchase of equipment, computing devices, or restock materials and supplies in anticipation of grant expiration where there is little, or no time left for such items to be utilized during the period of the award is highly discouraged. In situations where an item is necessary to complete the research, the benefit to the award and an allocation methodology should be determined and/or sponsor approval obtained. 

Departments / Principal Investigators will be held responsible to maintain and provide such documentation.  Any expenditure made for budgetary convenience is not allowable. 

Refer to Close Out an Award - End-of-Award Expenditures for additional information on equipment expenditures near the end of the project.