Financial Responsibility for Sponsored Projects Policy

The University at Buffalo (UB, university) accepts external financial support for research, training, and other activities and agrees to comply with the conditions of the support through sound financial management practices. The Principal Investigator (PI), and in part their college or school, is responsible for maintaining the financial integrity of a sponsored project including compliance with all terms and conditions of the award, managing funds within the approved budget, initiating requests for budget and program changes, and submitting technical reports and non-financial project deliverables.

The college or school to which credit is assigned for a sponsored project is responsible, in proportion to credit assigned to it, for all costs charged to that sponsored project. Costs charged to a sponsored project that Sponsored Projects Services (SPS) determines will not be recovered from the sponsor will be transferred pro rata to credited entities. The following circumstances may result in an unrecoverable cost:

• Costs that are unreasonable, unallocable, or unallowable under the sponsor’s award terms and conditions
• Expenditures in excess of the awarded amount
• Non-payment resulting from project non-performance
• Salary overpayments resulting from departmental negligence
• Dispute between the PI and sponsor
• Delinquency of payment by the sponsor due to financial distress, bankruptcy, or other causes not related to performance of the project

In the event that a college or school does not move an unrecoverable cost from a sponsored project in a timely manner, SPS will move the cost to the college or school indirect cost recovery allocation.

This policy assigns responsibility to the PI for ensuring that only reasonable, allocable, and allowable costs are charged to sponsored projects. The policy also requires the timely removal of unreasonable, unallocable, unallowable, and uncollectible costs from sponsored projects.

This policy applies to all PIs who administer sponsored projects.

Credited Entity

Unit, college, or school to which a sponsored project is assigned; a sponsored project may be assigned to multiple units.

Principal Investigator

UB faculty or staff member who bears responsibility for the leadership of a project, program, or activity. The PI accepts overall responsibility for directing the research, financial oversight, and compliance with relevant university policies and sponsor terms and conditions.

Sponsored Award

The funding mechanism, usually a grant, cooperative agreement, or contract, used to support a sponsored activity. A sponsored award generally contains expressed terms and conditions governing how the funds are to be administered.

Sponsored Project

Any externally funded research, training, evaluative testing, or public service project directed by UB faculty or staff as part of their university work that requires the university to perform a specified program or deliver a specified product.

• Know which sponsored project costs are reasonable, allocable, and allowable.
• Know whether funds are available when financial transactions are initiated.
• Know which budget changes require prior approval and submit timely requests for prior approval to SPS.
• Review account statement for accuracy at least monthly and request corrections within 30 days of account review, but no later than 30 days after the expiration of the account.
• Advise department chair, dean, and SPS of information indicating that the sponsor may be unable or unwilling to make payments.

• Inform SPS of information concerning potential delinquent payment or non-payment.
• Identify non-sponsored funds to cover unrecoverable sponsored project costs.
• Work with SPS to move unrecoverable costs to non-sponsored accounts within 10 days of receiving notice from SPS.

• Move an unrecoverable cost to the appropriate indirect cost recovery allocation account when a college or school does not move the unrecoverable cost in a timely manner.
• Negotiate awards to minimize the risk of non-payment or delinquent payment by sponsors.
• Provide information concerning any award requirements or deadlines to PI’s, in a timely manner.
• Provide guidance to PIs, deans, Unit Business Officers (UBOs), and others as appropriate regarding transactions that would result in an unrecoverable direct cost charge to a sponsored project.
• Notify cognizant deans of unrecoverable sponsored program costs.
• Pursue delinquent payments, including negotiation of late payment schedules and collection law suits.

• Identify salary overpayments and communicate to the PI and SPS.
• Determine the cause of salary overpayments.
• Work with Financial Management to collect overpayments, minimizing write-offs.

• Lead and track all overpayment collection efforts in conjunction with RF requirements.
• Process write-offs to the appropriate accounts for uncollectable overpayments.