It is the fiduciary responsibility of departments, schools and the University to ensure that project expenditures are allowable, reasonable, allocable, consistently treated and in keeping with the terms and conditions of the award. To this end the sponsor may require a formal financial report on a monthly, quarterly, semi-annual, annual, and/or final basis. The specific reporting requirements, level of detail and frequency can be found in the terms and conditions of the award.
(A.) Types of Financial Reporting Requirements
Some sponsors require frequent and detailed reports. In instances where the sponsor requires cost breakdown by task or a level of detail that cannot be obtained from the PER or DL, the department will need to collect this information and help to complete the financial reports. These reports must be sent to OSP for review, institutional approval and submission to the sponsor.
Many federal agencies require the submission of annual and/or final financial reports at the end of each budget period and/or end of the project. The terms of the award specify frequency, due dates (within 90 days for NIH) and the financial reporting form and/or format. (The Financial Status Report (FSR) is a form used by the NIH among other federal agencies.) The financial report preparation process requires that departments complete a reconciliation of expenditures for the award and ensure that all appropriate charges are posted to the G/L. OSP works with the department to complete the financial reports.
If there is cost sharing on the project, the sponsor may require the reporting of the actual non-sponsored cost share dollars in the Financial Status Report. The cost share dollars and account number must be documented by the department and forwarded to OSP for inclusion in the FSR and record retention.
Some federal agencies (such as NSF) or award types (such as e-SNAP NIH non-competes or NIH Fellowships) do not require the submission of an annual and/or final report. However, the University still must ensure that project expenditures are allowable and are consistent with the terms of the award. To assure compliance, OSP conducts an annual review of expenditures and will contact the department if there are any questionable transactions, variances on restricted budget categories or if large unexpended balances are identified in the course of the review.
(B.) Types of Invoicing
An invoice detailing costs
When an invoice is required by a sponsor (usually under a cost reimbursement award) the format usually includes the itemization of expenditures incurred during the invoice period and cumulative expenses to date in accordance with the major cost categories of the approved budget.
A single line item invoice
A single line item invoice is required usually under a fixed price contract*. This simple format consists of a one line narrative that specifies the price for services rendered, deliverables submitted and or milestones achieved during a specified time frame/schedule.
(C.) Institutional Approval
In all cases, OSP works with the department to complete report/invoice preparation and submission. OSP is the institutional representative and is responsible for signing and submitting financial reports to the sponsor on behalf of the University.
Departments sometimes prepare the invoice or provide OSP with additional supporting documents because of the level of detail required by the sponsor (i.e. costs breakdown by task, or salary breakdown by individual effort % etc.) These reports/invoices must be submitted to OSP in order to obtain institutional approval prior to submission.
Deadline for most final invoices is within 45-60 days after the award end date. Sponsors may NOT honor reimbursement on invoices submitted after 45-60 days. Similarly, a sponsor may not honor a single line item invoice if services or deliverables were not performed according to the required schedule.
Contact your OSP representative for additional information and assistance.
*Firm Fixed Price: This type of contract is appropriate when reasonable definite design and performance specifications are available, and a fair and reasonable price can be established at the onset of the requirement. A firm fixed-price contract provides for a price that is not subject to adjustment on the basis of the contractor’s cost experience in performing the contract. This contract type places upon the contractor maximum risk and full responsibility for all profit or loss (“Understanding NCI Contracts," a handbook produced by National Cancer Institute, Office of Acquisitions).