New York University Skip to Content Skip to Search Skip to Navigation Skip to Sub Navigation

POLICY

Internal and External Audit Policy for Sponsored Programs

Click here to download the Policy PDF

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) Circular A-133 (http://www.whitehouse.gov/sites/default/files/omb/assets/a133/a133_revised_2007.pdf), as well as all other applicable sponsor, state and city requirements.

Purpose of this Policy

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.

Scope of this Policy

This policy is applicable to all schools, departments, units and personnel of the University involved in managing sponsored awards including contracts.

Procedures for Implementation

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.

a. Internal Audits

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.

b. External Audits

i. Sponsor Audit, Program Audit or Financial Review

  • Programmatic Audits- The department must notify the Office of Sponsored Programs (OSP).
  • Financial Audits or Reviews- The department must notify SPA which will be the primary point of contact for completing the audit. SPA will coordinate the audit and collaborate with the department, as necessary, to develop a response and submit correspondence. The department should not send correspondence directly to the sponsor.

ii. NYU’S Annual Audit

Compliance Audits (A-133):

During annual A-133 audits, SPA will be present at all meetings including internal control discussions with Principal Investigators and Department Administrators. All documentation should be forwarded to SPA for review and submission to auditors and sponsors.

The OMB Circular A-133 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.

Click here to download the Policy PDF

Notes
  1. Dates of official enactment and amendments: 09/01/13
  2. History: blank
  3. Cross References: blank

About This Policy

Effective Date: September 01, 2013
Supersedes: N/A
Issuing Authority: Sponsored Programs Administration
Responsible Officer: Assistant Vice Present, Post-Award Administration

 

Federal Regulations

 


NYU Approach and application of this policy, related resources and more available in the Handbook.

Sponsored Programs Administration Post-Award Handbook

NYU Approach and application of this policy, related resources and more available in the Handbook.
Read More

NYU Footer