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Policies, Procedures and Guidance

GIM 15 – Accounting Adjustments on Sponsored Awards

Contents

Purpose
Background
Policy

Responsibilities
Other Related Resources

Purpose

This GIM sets out the policy for the administration of accounting adjustments for sponsored award funds consistent with federal and state regulations and sponsor policies.

Background

Federal and state regulations, sponsor policies, and audit guidelines are stringent as they relate to accounting adjustments that involve a sponsored award. Costs allocable to a sponsored award may not be transferred to another sponsored award in order to resolve a deficit, use an unspent balance, or other fund considerations, to avoid restrictions imposed by law or by terms of the sponsored award, or for other reasons of convenience per cost principles set out in the Uniform Guidance.

Campus Units and departments must have procedures in place which ensure accurate accounting for costs and timely correction of errors.

University Policy

All costs direct-charged or cost shared to awards must meet the cost principles per 2 CFR 200 Subpart E. Accounting adjustments where expense is moved from or to an award must be made within 90 days of when the error is discovered.

If an accounting adjustment is requested more than 120 days after the transaction date, an additional explanation for why the adjustment is late must be included and available for reference. The 120 days begins when the transaction is originally posted and ends when the adjustment is completed.

All accounting adjustments require a reason for the error and departments must maintain and provide convincing evidence that the goods and/or services are properly allocable. This explanation and evidence should also indicate that the receiving award benefitted from the goods and/or services involved.

Accounting Adjustments

The following information must be included on all accounting adjustments:

  • The reason(s) for the accounting adjustment must be stated to establish that the adjustment is within the approved guidelines of the award to be charged and is in direct support of the project objectives.
    • It is important to stress the benefit to the award receiving the cost in all instances.
  • The reason(s) the expenditure was initially charged to incorrect funds.
  • Transactions 120 days after the transaction date require an explanation for the timing of the adjustment must be included.

Note: Accounting adjustments involving equipment are reviewed by the Equipment Inventory Office, in addition to reviewers for awards.

Documenting Payroll Accounting Adjustments

The same principles apply to payroll accounting adjustments as to non-payroll adjustments. The following additional procedures apply to payroll accounting adjustments. Payroll Accounting Adjustments are reflected on project and effort statements within Employee Compensation Compliance (ECC) the following day. Review Effort Reporting Guidance in GIM 35.

Consistency Between Payroll Documents and Effort Reports

It is essential that the salary distributions be consistent with certified effort statements. When the salary distribution reflects a material difference from the actual effort distribution, a payroll accounting adjustment must be submitted to bring salary distribution into alignment with actual effort. In addition, payroll distributions should be reviewed at least quarterly and corrected if necessary to ensure that current and future distributions reflect the correct allocation of effort. If payroll accounting adjustments occur after effort has been certified, a recertification may be required. See GIM 35.

Late Awards

Care should be taken to not start work on a project before funding is assured. When an award is late, or award set-up is delayed, payroll accounting adjustments and accounting adjustments should be avoided by using the University’s procedure for obtaining Advance Spend. See GIM 9 Advance Spending on Sponsored Awards. When it is not possible to establish Advance Spend, other sponsored awards must not be used on an interim basis to “park” expenditures.

Responsibilities

Principal Investigator

  • Authorizes the proposed budget for submission to the sponsor
  • Monitors expenditures on a sponsored award
  • Authorizes accounting adjustments, when appropriate
  • Ensures internal controls are adhered to for appropriate allocation of costs to sponsored awards, see GIM 2

Campus unit/Department

Works with GCA to resolve late posting charges and to secure sponsor approval when necessary.

Department or School/College

Ensures appropriate internal controls are in place for appropriate allocation of costs to sponsored awards, see GIM 2.

Grant and Contract Accounting

  • Establishes awards and advance spend in the financial system of record
  • Works with department for securing sponsor approval on late posting charges
  • Prepares financial reports, invoices, and final reconciliations to support timely closeout of all sponsored awards

Other Related Resources

Contacts

Accounting adjustments involving sponsored awards: Grant & Contract Accounting, gcahelp@uw.edu

Accounting adjustment compliance: Post Award Fiscal Compliance, gcafco@uw.edu

Change Notes

Details on changes to this GIM are available from the Office of Sponsored Programs, osp@uw.edu