Adjustments on Finals Policy

POLICY AND PROCEDURE

Effective: 10/01/2022
Last Reviewed: 09/23/2022
Owner: Jill Frazier Tincher
Area: Sponsored Projects Admin
Applicability: UGA System‐Wide

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PURPOSE:
The purpose of this policy is to ensure compliance with the standards set forth in the Federal
Office of Management and Budget 2 CFR 200 Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards (2 CFR 200), Federal and State
regulations, and sponsor-specific requirements. This policy provides guidance, which will assist
University of Georgia (UGA) personnel proposing, performing, and managing sponsored
activities. Direct costs on sponsored projects must be allowable, allocable, and reasonable.
Failure to comply with UGA policies and procedures may result in audit findings, suspension of
sponsored activities, closer monitoring by the sponsor, delays in final payments, and/or other
enforcement actions imposed by the sponsor. This policy applies to all Federal and non-Federal
sponsored activities, including all externally funded activities.

SCOPE:
All UGA personnel must be aware of the complex and detailed rules provided under Federal,
State regulations, as well as terms and conditions of individual sponsored activities.

POLICY:
Sponsored projects will comply with all applicable Federal, State and/or sponsor-specific
policies. This is applicable to initiating, approving, invoicing, collecting, and reporting costs.
Sponsored Projects Administration (SPA) must submit all final invoices and financial reports on
sponsored activities timely and accurately in accordance with the sponsor-specific requirements.
Final invoices and financial reports are submitted to the sponsor when required and are prepared
based upon the required format, form, and frequency.
To ensure invoices/financial reports are accurate, all expenses charged to sponsored projects
must adhere to the Direct Cost Policy. According to the university Financial Review and
Analysis policy, all University of Georgia departments are responsible for reviewing
reasonableness and accuracy of financial transactions recorded in the University’s financial
systems within 30 days of the prior month end. Additionally, the Proactivity for Budget Year
and Award Closeout Tool is available and recommended for use by PIs/units to ensure all
projects are regularly reviewed. This enables the PI/unit to confirm all direct expenses are
allowable, allocable, and reasonable. If discrepancies are identified, the discrepancy/ies can be
immediately corrected.
To meet the sponsor requirements for timely submission of financial invoices/reports, SPA Post
Award will generate invoices/reports based upon expenditures posted to the sponsored project in
the UGA Financial Management System within 45 days after the project end date. This ensures
accurate invoicing, recording of revenue and aging of accounts receivable. Manual adjustments
on finals will be approved in rare circumstances as described in the Procedures section of this
policy.

DEFINITIONS:
Department Administrator has responsibility for assisting PIs (Principal Investigators) in
discharging their monitoring responsibilities, for reviewing invoices from subrecipients, and
seeking clarification on questionable expenditures, if/when necessary, and for maintaining
appropriate documentation.
Direct Costs are reasonable, allowable, and allocable. They can be easily identified with a
specific sponsored project and can be directly assigned based upon proportional benefit with
relative ease and a high degree of accuracy. Costs incurred for the same purpose in like
circumstances must be treated consistently as either direct cost or indirect costs. Typical costs
charged directly to sponsored activities include personnel (salaries and fringe benefits); materials
and supplies; scientific equipment; travel; and other expenses necessary to conduct the sponsored
activity.
Indirect Costs (Facilities & Administrative) are costs incurred for a common or joint purpose
benefiting more than one activity/project and therefore, cannot be easily and readily
assignable. Indirect Costs include the costs of operating and maintaining general-purpose
equipment and facilities, general administration (human resources, departmental administration,
procurement, accounting, and sponsored project administration) as well as general expenses
(general-purpose supplies, postage, telephones, and other office equipment).
Principal Investigator (PI) has primary responsibility for overseeing the scientific and financial
aspects of a sponsored project including monitoring subrecipients to ensure compliance with
Federal regulations regarding both prime and subrecipient award terms and conditions.
Sponsored Projects are externally funded activities that must be separately budgeted and
accounted for according to terms of the sponsoring organization, State regulation, and UGA
policy. Sponsored Activities are provided through grants, contracts, and agreements with any
Federal Agency, State Agency, or non-Governmental Organization that supports research,
training, instruction, public service, and other activities.
Sponsor-specific Requirements include requirements stated within the sponsor rules/regulations,
funding opportunity announcement, award/grant or contract/agreement and amendments.

PROCEDURE:

  1. During the life of all sponsored projects, PI/unit must:
    1. Initiate expenses consistent with the Direct Cost Policy.
    2. Analyze all transactions monthly to confirm budget, expense and encumbrances
      are allowable, allocable, and reasonable.
    3. Regularly follow the Proactive Steps for Award Management
    4. Ensure all expenses are posted to the project within 45 days following the project
      end date. Manual adjustments will only be considered on rare occasions.
  2. On the rare occasion where a sponsor has a stricter reporting/invoicing requirement,
    which is, less than 45 days following the project end date, PI/Unit can initiate and submit
    the Adjustments on Finals Request Form to the SPA invoicing team member. This form
    should identify expenses, which have not yet been posted but should be included in the
    final invoice/report. SPA Post Award will review the form.

    1. If approved, those expenses will be included within the final invoice/report.
    2.  If the form is not approved, those expenses must be moved to a departmental
      fund.

RESOURCES:
2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards