POLICY AND PROCEDURE
Last Reviewed: 09/23/2022
Owner: Jill Frazier Tincher
Area: Sponsored Projects Admin
Applicability: UGA System-Wide
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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.
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 (i.e., research, public service and outreach, instruction, and cooperative extension).
All UGA personnel must be aware of the complex and detailed rules provided under Federal and State regulations, as well as terms and conditions of individual sponsored activities.
Sponsored projects will comply with all applicable Federal, State and/or sponsor-specific transfer policies. When a PI intends to relocate, he/she must consider each sponsored project and recommend their appropriate disposition. Potential dispositions include:
- Complete all work and close the sponsored project prior to departing;
- Recommend the sponsored project transfer to another PI at the existing institution;
- Recommend the sponsored project transfer to the new institution; or
- Close the sponsored project without completing all work.
When assessing if a sponsored project should transfer from one institution to another, please consider: when the project is ending; what funds are remaining; if co-investigators are involved; if/how many subrecipients are involved; if graduate students will continue their education at the original institution; and if the project involves unique populations/samples (human subjects, animals, etc.). All of these can influence if the sponsored project transfer should/can occur.
This policy is applicable to the University of Georgia facilitating sponsored project transfers – into and out of UGA – as appropriate.
- When a Principal Investigator (PI) intends to relocate from UGA and to a new institution, it is the PI’s responsibility to work with his/her college/school/unit to submit a request through Sponsored Projects Administration (SPA) for the relinquishment of each sponsored project. Sponsored Projects are awarded to UGA/UGARF, not the PI; therefore, UGA/UGARF have the ultimate authority to determine if the sponsored project is retained or relinquished to the PI’s new institution. If it is determined that the sponsored project will transfer to another institution, the PI/college/school/unit will work with SPA to reconcile and close out each project reflective of work/expenses incurred at UGA. Then, SPA will work with the sponsor and new institution to facilitate the transfer.
- When a PI intends to relocate from another institution and to UGA, it is the PI’s responsibility to provide his/her college/school/unit the necessary sponsored project information. The college/school/unit will work with SPA to provide the necessary documents and approvals. Then, SPA will work with the sponsor and the prior institution to facilitate the transfers.
Department Administrator has responsibility for assisting PIs in discharging their monitoring responsibilities, for reviewing invoices from subrecipients, and seeking clarification on questionable expenditures, if/when necessary, and for maintaining appropriate documentation.
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, Federal/State regulations, 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.
A subrecipient is a third-party, non-Federal entity that receives a subaward from a pass-through entity to carry out part of a sponsored project; but does not include an individual that is a beneficiary of such project. A subrecipient may also be a recipient of other awards received directly from a third-party.