Grant Internal Controls

Internal control processes and procedures for Grant Accounting at Central Michigan University.

Closing checklist for cost centers

A closing checklist should be used when closing a grant account. The checklist and grant file will flow to the appropriate accountants until the checklist is completed. An accountant will sign the checklist when it is complete. The closing checklist will be filed in the grant file.

Closing checklist for Grants Management (GM) system

Deficit policy

Deficits (overdrafts) on sponsored programs and budget disallowances are the responsibility of the project director. The project director is responsible for finding a suitable source of funding to cover the deficit whether it is from other funds available to the project director, or from the department, school/responsibility center or campus.

Departments are only permitted to spend up to the authorized award amount as stipulated in the grant or contract during the award period. Departments exceeding the authorized spending amount will be liable for all excess spending amounts. Failure to comply with the terms of the grant or contract may result in the grant or contract being temporarily terminated and the project closed.

End date cut-off

Grant Accounts will be set up in the computer system (SAP) with an additional 30 days added to the grant end date. In Grants Management (GM), you will see this grace period in the Budget and Posting tabs of the Grant Master Data screen. This date extension will allow for postings to flow through to the grant account without interruption until that day has been reached. This end date extension is necessary to allow for postings that are processed monthly (i.e. credit card charges, telephone). After the 30-day grace period has expired, SAP will automatically disallow any further postings.

Final narrative report requirements

Upon termination of the award, the Principle Investigator (PI) is responsible for submitting the final narrative report to the sponsor within the time frame specified. Failure to submit this report in a timely manner may jeopardize future funding by the sponsor. A copy of an award’s final narrative report must be submitted to the Grant Accounting Office. The report will be added to the Award file.

Journal entry on grants and contracts

A journal entry is used to either record an initial charge or to record a cost transfer. Care should be taken in the distribution of expenditures so that costs are charged initially to the correct project. Text or notes field should contain sufficient information to allow for a proper audit trail of the transaction. Written approval from individuals with signature authority must be evidenced in a memo, on a request form, or via electronic means. The originator of the journal entry must attest to the following – the allocation is being processed in accordance with policy, the cost is an appropriate charge to the project sharing the expense, the project actually benefited from the cost of the goods and services, and the transaction is documented according to policy. Ensure correct General Ledger account is being used when preparing journal entry. Paper documentation must be maintained according to the University’s record retention policy by the Department. It is also imperative that the Department implement internal procedures that allow for paper documentation to be readily accessible in the event the transaction is required during an audit.

Net difference in compensation

Net difference in compensation is generated when salaries and benefits are paid to an individual from a grant or contract and the budget does not have sufficient funds to cover the amount of the individuals’ salaries and benefits. The department will need to fill out a Faculty Personnel Transaction Form and forward to the Office of Research and Sponsored Programs (ORSP) for approval. ORSP will forward the form to Faculty Personnel Services where they will calculate the net difference in compensation and determine the funding source. A copy of the form will be forwarded to Accounting Services where the funds will be transferred from the department to the grant/contract.

When the grant accountant receives the form from Faculty Personnel Services, the accountant will need to establish the internal WBS element number if needed, and enter the budget for the net difference in compensation amount.

Opening checklist

An opening checklist should be used when opening a new grant or contract account. The checklist and the file will be forwarded to each accountant as necessary until the checklist is completed. An accountant will sign the checklist when it is completed. The opening checklist will be filed in the grant/contract file.

Payments to third parties

Payments to a third party are first subject to the availability of funds. The costs must also be allowable, reasonable and allocable to the sponsored project agreement. The costs must be fully documented and copies should be kept by whoever processes the request.

The request for a payment from a grant account to a third party must be done by filling out an invoice voucher. A copy of the invoice voucher form can be found on the Payable Accounting website.

You can also find an invoice processing checklist on the Payable Accounting website that will help ensure more accurate and timely invoice processing. Payable Accounting will process the invoice voucher and create the payment.

Reconciliation of federal online draws

To ensure accuracy and uniformity in the preparation and reconciliation of financial data, all internally prepared accounting records, data submission and other accounting data are periodically reviewed and reconciled with reports generated online by the sponsor. SAP is the University’s official record-keeping system, therefore the sponsor’s online draw information will be reconciled to SAP. Reconciliations of draws done online are performed by comparing the University’s customer account (114300) to the sponsor’s online cash disbursement report. In addition to reviewing draws, total awarded amounts and unexpended balances are also reviewed for accuracy and error handling. To safeguard the University’s interest and for security purposes, the login access to these online sites are password protected and only provided to one authorized individual.

Reporting checklist

For completeness and accuracy of the A-133 report, a checklist should be used. The purpose of the checklist is to ensure all federal awards that are assigned a CFDA (Catalog of Federal Domestic Assistance) number are included in the A-133 report. Federal award means Federal financial assistance and Federal cost-reimbursement contracts that non-Federal entities receive directly from Federal awarding agencies or indirectly from pass-through entities.

Signature authority

Signature Authority is granted to a project director. The project director may grant signature authority to an additional signer by completing the Signature Authority Form or in another means of written communication. The written approval must be from the project director and the additional signer must also give written acceptance. The additional signer should be aware that by signing grant-related documents, they are attesting that the charges are allowable, reasonable and allocable to the project. The original Signature Authority Form must be given to the grant accountant in WA304 or WA307. When the Signature Authority Form is received by Grant Accounting, the grant accountant will fill in the date the form was received. The form is then filed in the grant file.