Financial Reporting for Sponsored Programs Policy
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It is the policy of New York University (NYU, “the University”) to comply with the requirements of the Federal Office of Budget and Management (OMB) Circular A-110, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and other Non-profit Organizations (http://www.whitehouse.gov/omb/circulars_a110/) and Federal Demonstration Project (FDP) - General Terms & Conditions (http://www.nsf.gov/pubs/fdp/fdp405a110.pdf) for financial reporting.
Purpose of this Policy
The purpose of this policy is to provide guidance for submitting accurate and timely reports in compliance with Federal regulations and other sponsors requirements.
Scope of this Policy
This Policy is applicable to all schools, departments, units and personnel of the University involved in administering sponsored awards.
Procedures for Implementation
Listed below are the responsibilities, procedures and tools available for developing financial reports for sponsors.
a. Roles and Responsibilities
Principal Investigators (PI's) and Departmental Administrators (DA's)
- The PI is ultimately responsible for monitoring all financial aspects of the sponsored project and ensuring accuracy of the financial information reported to the sponsoring agency. This includes reviewing the cost analysis and ensuring any adjustments are processed in PASS and/or JEMS timely so that the system reflects any adjustments to the final financial reports.
- Work with Sponsored Programs Administration (SPA) to ensure financial reports are accurate and submitted timely to sponsor.
- After reviewing and approving the final financial report that SPA will submit to the sponsor, the PI and or DA will provide the date of submission of the final progress report to the sponsor.
- Follow procedures outlined in the Award Closeout Policy for Sponsored Programs or final reports (technical, financial, and other reports).
- To assist PIs and DA's to monitor the financial administration of their awards, there are a number of financial reports available. See Appendix 1 of this policy for a complete listing of these reports.
Sponsored Programs Administration (SPA)
- Work with PI's and DA's to complete financial reports.
- Provides the department with a cost analysis to identify any unallowables or request supporting documentation and justification for potential questionable costs.
- Updates cost analysis for adjustments/comments provided by the department.
- Works with departments to ensure approval has been obtained for interim reports where carry-forward prior approval is required.
- Prepares and submits all financial reports in accordance with sponsor requirements and the NYU Award Closeout Policy for Sponsored Programs.
- Verifies submission of final progress reports by the PI.
b. Federal Awards: Federal Financial Reports (SF 425)
SPA is responsible for submitting all Federal Financial Reports (also known as FFRs). These reports are normally submitted on a quarterly, semi-annual or annual basis, as directed by the Federal agency in the Federal Award. A final FFR shall be submitted at the completion of the award agreement. For final FFRs, the reporting period shall be the end date of the project or grant period.
- Quarterly and semi-annual interim reports shall be submitted no later than 30 days after the end of each reporting period.
- Annual reports shall be submitted no later than 90 days after the end of each reporting period.
- Final reports shall be submitted no later than 90 days after the project or grant period end date.
c. Other Awards: Report of Expenditures (also known as ROEs)
This report summarizes the expenditures incurred for a time period – e.g., monthly, quarterly, annually – based on the original budget, along with any revisions. Typically, foundations and private sponsors use this type of report for reporting financial information. Some sponsors stipulate a deadline for reports of expenditures, and some do not. In all circumstances, NYU follows the 90-day requirement if no deadline is imposed by the sponsor.
d. Non-Financial Reports
At the time of final financial reporting, the SPA Analyst will request the department provide the submission dates for the final progress or project report as required by the sponsor. SPA does not require copies of these reports.
Final reports (financial and technical) should be prepared in accordance with the Award Closeout Policy for Sponsored Programs.
Click here to download the Policy PDF