|Title:||Governing and Cost Accounting Standards|
|Policy Owner:||Office of the Vice President for Research, Sponsored Program Services|
|Applies to:||All Faculty, Staff, and Students|
|Campus Applicability:||All campuses|
|Effective Date:||November 18, 2019|
|For More Information, Contact||Office of the Vice President for Research, Sponsored Program Services|
|Contact Information:||860-486-3622 (Storrs and regional campuses)
860-679-4040 (UConn Health)
|Official Website:||https://ovpr.uconn.edu (Storrs and regional campuses)
https://ovpr.uchc.edu (UConn Health)
REASON FOR POLICY
To confirm sponsored programs are administered in accordance with award requirements such as the Uniform Guidance, Cost Accounting Standards for Educational Institutions, Federal Acquisition Regulations, Federal and State regulations, and sponsor and university policies.
All faculty, staff, and students involved in the administration of sponsored programs at the University of Connecticut, regional campuses, and UConn Health (“University”).
This policy establishes the terms and conditions that govern sponsored projects. The University will be responsible for determining the appropriate costing treatment and for the maintenance of the CAS Disclosure Statement (DS-2) as prescribed in 2 C.F.R. §200.419.
In accepting a sponsored program, the Institution and Principal Investigator(s) assume responsibility for fulfilling the requirements of the program. These requirements may be specifically contained in the agreement or they may be incorporated by reference to guidelines issued by the sponsor in special publications or directives.
Cost accounting and financial compliance for federally funded sponsored projects at the University is dictated by various Federal Office of Management and Budget Circulars and agency regulations.
The following is a brief explanation of the major bodies of federal and agency regulations that address financial compliance related to sponsored programs:
Uniform Guidance (2 CFR Part 200)
The Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) establishes a basis for policy in the management of federally sponsored programs.
Specifically, the Uniform Guidance sets forth the uniform administrative requirements for grant and cooperative agreements, including the requirements for Federal awarding agency management of Federal grant programs before the Federal award has been made, and the requirements Federal awarding agencies may impose on non-Federal entities in the Federal Award. The Uniform Guidance also establishes the principles for determining the allowable costs incurred by non-Federal entities under Federal awards. Finally, the Uniform Guidance sets forth standards for obtaining consistency and uniformity among Federal agencies for the audit of non-Federal entities expending Federal awards.
Federal Acquisitions Regulations (FAR) (48 CFR)
Establishes the policies, procedures, and requirements of Federal contracts.
Cost Accounting Standards (48 CFR 9905)
Standards designed to ensure uniformity and consistency in the measurement, assignment and allocation of costs to contracts with the US Federal Government, and include:
CAS 501 – Consistency in Estimating, Accumulating and Reporting Costs
University will ensure compliance by employing consistent practices when developing budgets for proposals and in accounting and reporting costs for program expenses (in accordance with Federal and State rules and regulations and University policy).
CAS 502 – Consistency in Allocating Costs Incurred for the Same Purpose
Costs incurred for the same purpose, in similar circumstances, must be given consistent treatment in the accounting system. All costs must be charged consistently as either a direct cost or as part of the federally negotiated Facilities & Administrative (F&A) cost structure.
CAS 505 – Accounting for Unallowable Costs
Unallowable costs (as defined by federal, state or university regulation or policy) must be identified and excluded from any billing, claim, or proposal submitted to the Federal government.
CAS 506 – Cost Accounting Period
The University Fiscal Year (July 1 – June 30) will be used as the accounting period regardless of the sponsor’s accounting period.
Federal Sponsor Guidelines
While the Uniform Guidance establishes the principles for sponsored program management, each federal agency may differ in policy application. Additionally, terms and conditions specific to an award may apply.
Non-Federal Sponsor Guidelines
The specific award agreement, together with University policy, usually guides the project’s conduct. State agencies, foundations, and private businesses may also publish their own funding guidelines and requirements.
ROLES AND RESPONSIBILITIES
Responsible for ensuring appropriateness of all charges on sponsored projects. Ensure the consistent application of direct costing practices to sponsored projects.
Department or Shared Services Fiscal Officer/ Administrator
Assists the Principal Investigator in ensuring consistent application of costing practices, record keeping and other financial and administrative requirements.
Sponsored Program Services
Develop and maintain policies and procedures in accordance with Federal regulations. Provide training and guidance to Principal Investigators and staff. In accordance with policy and procedure, review transactions for appropriateness under Federal and institutional guidelines.
Office of Cost Analysis (Storrs and regional campuses) / Research Finance (UConn Health)
Maintain and file CAS Disclosure Statement (DS-2) in accordance with §200.419 identifying accounting practices, policies, and procedures for assigning costs to federally sponsored programs, and to attest to the consistent treatment of those practices.
Violations of this policy may result in appropriate disciplinary measures in accordance with University Laws and By-Laws, General Rules of Conduct for all University Employees, applicable collective bargaining agreements, and the University of Connecticut Student Code.
PROCEDURES/FORMS/ OTHER POLICY
UConn Storrs and Regional Campuses:
Policy created: Approved by the President’s Cabinet on 09/12/2019. This is a new University wide policy to better document practices at Storrs and regional campuses and combines two previous policies at UConn Health.
Miscellaneous guidance at Storrs and regional campuses
UCH Policy 2002-12, “Governing Standards”, 2/25/2002
UCH Policy 2002-37, “Cost Accounting Standards”, 2/25/2002