Effective Date Supersedes 09/01/13 Issuing Authority Sponsored Programs Administration Responsible Officer Assistant Vice Present, Post-Award Administration
It is the policy of New York University (NYU, “the University”) that the University responds to all internal and external audits and financial reviews of sponsored awards in a manner that is in compliance with all applicable Federal requirements, including the Federal Office of Budget and Management OMB Uniform Guidance (OMB Uniform Guidance), as well as all other applicable sponsor, state and city requirements.
The purpose of this policy is to provide guidelines for the proper management and response to internal and external audits and financial reviews of sponsored programs.
This policy is applicable to all schools, departments, units and personnel of the University involved in managing sponsored awards including contracts.
All audits of sponsored programs are coordinated by Sponsored Programs Administration (SPA). Principal Investigators (PI’s) or Department Administrators (DA’s) contacted by a sponsor intending to perform an audit or financial review of a sponsored project should immediately notify SPA.
Internal Audit performs audits of Sponsored Programs on a cyclical basis. These audits are performed to monitor compliance with sponsor terms and conditions as well as NYU policies and procedures. If contacted by Internal Audit, departments should immediately notify Sponsored Programs Administration.
The OMB Uniform Guidance report is submitted to the Federal Audit Clearinghouse. This report is a public document, which summarizes how the University has complied with sponsor requirements and internal policies and procedures in administering sponsored awards.
Terms and conditions of the Sponsor and Federal requirements dictate what expenses and activities are allowable. When administering awards, PIs and DA's should not assume that something is allowable because it was included in the approved budget. Any activity or expense that may not comply with the award terms and conditions should be discussed with SPA and OSP.
Intentional disregard of Federal requirements and University policies and procedures may lead to sponsor imposed administrative sanctions, damage to reputation, loss of current or future funding and/or in severe cases, imprisonment.