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3.10.5

Financial Resources: Control of sponsored research/external funds
The institution maintains financial control over externally funded or sponsored research and programs.

Judgment
  Compliant      Non-Compliant      Not Applicable

Narrative

Morehouse College has clear policies and procedures for both pre-award and post-award financial management of externally funded research and sponsored programs. In the pre-award phase, guidelines established by the Morehouse College Office of Sponsored Programs (OSP) for grant and contract submission provide procedures for correct calculations of salaries and fringe benefits. (See the Policies and Procedures Manual, Office of Sponsored Programs, Section AA 400.1). OSP also follows the guidelines of the applicable Office of Management and Budgets (OMB) Circulars. OMB Circular A-21 provides for the correct calculation of salaries, fringe benefits, travel and other parts of the budget included in the direct costs of a grant (Policies and Procedures Manual, Office of Sponsored Programs, Section AA 400.2).

Before a proposal can be submitted to an outside agency, it is reviewed by the Department Head to ensure that it fits within the plans and goals of the area and that the proposal writer has the capability of completing the proposed research. Once it has been approved by the Department Head, it is reviewed by the Dean to ensure that the area has both the funding to support any matching cost and the capacity to accommodate the project. The proposal is then subject to administrative review by the OSP to ensure that it conforms to the requirements of the Request for Proposal (RFP). It also requires the approval of the Senior Vice President for Academic Affairs, the Vice President for Institutional Advancement, the General Counsel and the Vice President for Business and Finance to ensure that the Institution is able to meet any cost sharing requirements and that the appropriate rates for indirect cost and fringe benefits were applied.  (See the Morehouse College Proposal Action Form, (PAF)).

In the post-award phase, the Office of Business and Finance also provides guidance for management of a grant or contract. The office of Grants and Contracts Accounting establishes a unique identifier for each funded project and communicates charge codes to the Principal Investigator. The office also establishes a file consisting of the grant award letter and the line item budget. Copies of both documents are forwarded to the Office of Financial Planning and for their review and setup in the Banner Accounting System.

The College’s Office of Financial Planning and Budgets reviews each proposed budget and enters it into the accounting system. All expenditures from the grant or contract must be requested by the Principal Investigator and reviewed by a Budget Analyst to ensure compliance with the guidelines spelled out in the approved budget document. All employees hired as a part of a grant or contract must be requested by the Principal Investigator, approved by the Dean and the area Vice President and authorized by the office of Financial Planning and Budgets and the Vice President for Business and Finance. Requests for travel are also reviewed to ensure that they fall within the guidelines of both the grant or contract and the College’s Travel Policies and Procedures. All contractual agreements associated with a grant must be reviewed by the College’s Office of General Counsel, checked for budget availability and authorized by the Vice President for Business and Finance prior to any expenditure being made. (See the College Policies and Procedures, Business and Finance, Sections BF 200 - BF 700).

In addition, the office of Grants and Contracts Accounting provides assistance with the reporting of cost-sharing, reporting of time and effort, post-award changes in the project, retroactive cost transfers, and close-out of the grant. The office is also responsible for ensuring that all quarterly expenditure reports and the annual financial status reports are filed on a timely basis. (See the Sample Quarterly Expenditure and Annual Financial Status Reports below).

The Morehouse College financial procedures for managing grants and contracts are governed by the College’s Business Policies and Procedures Manual and are in compliance with the requirements of the federal principles and guidelines (U.S. Office of Management and Budget Circular A-21, Cost Principles for Educational Institutions; U.S. Office of Management and Budget Circular A-110, Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations). Compliance with these policies is subject to periodic review by the Morehouse College Office of Internal Audit, the College’s outside auditors and federal or private grantor auditors. The most recent A-133 audit of the College’s Federal Student Aid awards and its Research Programs for fiscal 2005/06 is still in progress and the College has not been notified by the auditors of any major findings at present.

 
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