Policy RA02 - STEWARDSHIP OF SPONSORED PROGRAMS

Policy Steward:  Vice President for Research, and Corporate Controller

Contents:

  • Purpose
  • Policy Statement
  • Responsibilities
  • Compliance
  • Further Information
  • Cross References

  • PURPOSE:

    To establish appropriate policies for the stewardship of sponsored projects, and to identify the roles and responsibilities of all individuals participating in sponsored program administration.

    POLICY STATEMENT:

    Principal Investigators and others involved in management of sponsored awards are stewards of these awards and are financially accountable for using University resources wisely and executing these responsibilities with integrity.  Every employee who conducts transactions that affect University funds must be in compliance with all University policies, applicable laws, regulations, and special restrictions.

    RESPONSIBILITIES:

    Penn State recognizes that management of sponsored programs is a collaborative effort. All individuals involved in sponsored programs are expected to have read and understood all applicable policies and procedures in the University Policy Manual in GURU. This includes policies and guidelines related to Intellectual PropertyResearch AdministrationResearch ProtectionsSafety, and Travel. Below are the responsibilities for each of the positions involved with the management of sponsored programs:

    COMPLIANCE:

    False Claims Act (FCA)

    The False Claims Act (FCA) (US Code:  31 USC 3729) makes it a crime for any person or organization to knowingly make a false record or file a false claim with the government for payment.   This Act was further expanded through The Fraud Enforcement and Recovery Act of 2009 (FERA) (Public Law 111-21).  These and related amendments are applicable to the administration of federally sponsored research, and impose liability on any person who knowingly:

      1. submits a false or fraudulent claim for payment,
      2. causes such a claim to be submitted for payment,
      3. makes, uses, or causes to be made or used a false record or statement material to a false or fraudulent claim,
      4. conspires to get such a claim paid or approved, or
      5. makes a false record or statement to conceal or avoid an obligation to pay money to the government.

    Those managing federally sponsored awards, especially Principal Investigators, are subject to the False Claims Act and can be criminally prosecuted for mismanagement of federal funds.  Therefore, those managing these funds must take responsibility for understanding costing policies and the impact on their specific sponsored awards.

    Specific Issues Relating to Allocation of Costs

    PIs and others with responsibility for sponsored research need to be aware that:

    1. Any costs allocable to a sponsored project may not be shifted to another sponsored project in order to meet deficiencies caused by cost overruns, to avoid restrictions imposed by law or terms of the sponsored project, or for other reasons of convenience, even on a temporary basis.  In addition, any costs allocable to activities sponsored by industry, foreign governments, or other sponsors may not be shifted to another sponsored project. PIs must ensure that costs which benefit multiple projects are properly allocated to all projects based on a reasonable allocation method.
    2. When managing multiple awards, utmost care must be given to manage each award separately, and not to view the various sponsored awards as one large award pool.  Generalized costs allocable to different awards cannot be paid on one award one time and a different award the next time – the costs need to be allocated based on usage or another reasonable method for each incurred transaction.  The University's accounting system allows for the allocation of costs to multiple awards at the time of the transaction.

    See the Allocable Costs section of RA10 – Costing Principles for Sponsored Awards for additional details.

    Reporting Non-Compliance

    Anyone involved in sponsored award administration who believes that a non-compliance issue has arisen must contact the Research Administrator, Financial Officer or the Compliance Hotline. PIs and Co-PIs have the primary responsibility for assuring that all costs charged to the sponsored award are related to the project.  The PI should consult with the Research Administrator and/or Financial Officer regarding any questions about costing policies or specific award compliance issues.

    FURTHER INFORMATION:

    For questions, additional detail, or to request changes to this policy, please contact the Office of the Vice President for Research, or the Office of the Corporate Controller.

    CROSS REFERENCES:

    Other Policies may also apply, especially:

    RA10 - Costing Principles for Sponsored Awards

    RAG80- Sub-Recipient Monitoring (Formerly RAG22)

    RP06 – Disclosure and Management of Significant Financial Interests


    Effective Date: February 26, 2016
    Date Approved: February 22, 2016
    Date Published: February 26, 2016

    Most recent changes:

    Revision History (and effective dates):

    | top of this policy | GURU policy menu | GURU policy search | GURU home | GURU Tech Support | Accessibility Statement | Penn State website |