Principal Investigator

Principal Investigators (PIs) are responsible for their sponsored awards, including the management of the day-to-day operations of their award budgets. Budgets should be reconciled on a regular basis to provide reasonable assurance that transactions are necessary, reasonable, allocable, allowable, and consistently treated. Specifically, PIs are responsible for:

• Reviewing and approving the budget input form for the original budget and for any budget changes
• Spending award funds compliant with award terms and sponsor and university policies and processes (see Sponsored Projects Expenditure Guide for guidance)
• Adhering to SU contract review and procurement policies and obtaining bids, as necessary
• Documenting purchases (with receipts or other source documentation)
• Reviewing and approving subcontractor and subawardee invoices, as applicable
• Completing and submitting appropriate financial forms such as the sole source justification form, cost transfer justification form and institutional prior approval form, as applicable
• Reviewing and certifying quarterly financial reports provided by the Associate Controller
• Reviewing and certifying the annual Review of Compensation Charges, if applicable
• Identifying and resolving budget overruns in coordination with your budget manager via a journal entry and cost transfer justification form
• Initiating and proposing rebudgets of the approved grant budget using the Institutional Prior Approval Form
• Completes and certifies the Closeout Form at the end of the project

Divisional Budget Manager

The budget manager is available on a limited basis to support the PI with their responsibilities in carrying out their sponsored awards as detailed above. Specifically, Budget Managers are responsible for:

• Assisting in the preparation of and approving financial forms such as the Payroll Action Form and Faculty Stipend Request; Journal Entry and Cost Transfer Justification form; and Budget Input Form
• Supporting PIs with budget reconciliation, SU procurement processes, and rebudgets
• Reviewing and certifying quarterly financial reports provided by the Associate Controller
• Reviews and certifies the Closeout Form

Sponsored Research Officer

The Sponsored Research Officer (SRO) serves as a resource to PIs and Budget Managers throughout the administration of their award and is the primary liaison with the sponsor. Specifically, SROs are responsible for:

• Requesting the establishment of a new account when an award is received
• Setting up the initial budget input form and updating upon changes affecting the award budget
• Reviewing and supporting development of prior approval requests (such as rebudgets, changes in personnel or timeline), coordinating approvals with the sponsor as needed, and approving or denying such requests
• Initiating sponsored award closeout using the Closeout Form

Associate Controller

The Associate Controller maintains the official financial records for the university, including sponsored awards. Specifically, the Associate Controller is responsible for:

• Additional review of expenses to ensure they are necessary, allowable, reasonable, and allocable to the grant as well as in adherence with SU policies and, if applicable, Uniform Guidance
• Final review of Cost Transfer Justifications and processing Journal Entries
• Reviewing and documenting suspension and debarment compliance for all spending on federal awards
• Reviewing rebudgets and update grant budget within financial system
• Providing ad hoc financial reports, quarterly financial reports for audit certification and annual payroll certification report, and final financial reports for PI and University grant personnel
• Submitting financial reports for all federal agencies and coordinating with the Department Budget Manager and PI for private agency reporting (unless otherwise specified)
• Performing the reimbursement invoicing and cash draws
• Conducting subrecipient monitoring risk assessments and annual financial statement reviews
• Closing the project in the financial system after receiving the completed Closeout Form

Grant Accounting Roles and Responsibilities

Federal regulations establish four cost principles for determining costs applicable to awards. Seattle University applies these principles consistently across all sponsored projects.

All charges must be:

1. Allowable

Costs expressly unallowable or mutually agreed to be unallowable shall be identified and excluded from any billing, claim, application, or proposal related to a sponsored projects. Sponsoring agencies use the term "allowable" to mean permitted as a cost within sponsor guidelines, the terms of a specific award, and/or the institution's policies.

2. Allocable

A cost is allocable to a particular award if the goods or services involved are able to be directly assigned to the award based on the benefit provided. To determine if an expenditure is allocable, ask yourself the following questions:

• Is it incurred solely to advance the work under the award?
• Does it benefit the award and other activities, and can it be distributed to all benefitted activities using reasonable methods?
• Is it necessary to the overall operation of the institution and, in light of sponsored research rules and regulations, is it deemed to be assignable in part to the award?
• Does the basis for allocating the cost represent a reasonable estimation of the direct benefit provide to the award objectives?

If a cost is allocable to more than one award, please appropriately proportion costs by activity string within ProcureSU.

3. Reasonable

A cost may be considered reasonable if the nature of the goods or services, and the price paid for the goods or services, reflects the action that a prudent person would have taken given the prevailing circumstances at the time the decision to incur the cost was made.
To determine if an expenditure is reasonable, ask yourself the following questions:

• Is the cost a type generally recognized as necessary for the performance of the sponsored agreement?
• Does incurring this expenditure violate the restraints or requirements imposed by such factors as arm's-length bargaining, federal and state laws and regulations, or sponsored agreement terms and conditions?
• Have the individuals incurring this cost acted with due prudence (discretion and good sense) in the circumstances? Have they considered their responsibilities to the institution, its employees, its students, the Federal Government, and the public at large?
• Were the actions that were taken in respect to incurring the cost consistent with established institutional policies and practices applicable to the work of the institution, including sponsored agreements?

4. Consistently Treated

All costs incurred for the same purpose, in like circumstances, must be treated uniformly either as direct costs or as indirect (F&A) costs. Since certain costs, such as salaries of administrative and clerical staff and office supplies are normally treated as F&A costs, these costs cannot be charged directly to federal Awards unless the circumstances related to a particular project are clearly different from the normal operations of the unit.  

The PI/PD, with oversight by the Activity Manager, is responsible for spending the funds as proposed by the sponsor in adherence to the sponsor and university policies. All purchases within ProcureSU are also reviewed for allowability, allocability and reasonableness (as defined above) by the Grant Accountant prior to approval.

Please document the purpose of the purchase within the comments section of ProcureSU.

If you need assistance with processing grant-funded purchases, please contact Aika Foz, Grant Management Specialist.

Please review the Procurement Thresholds in the below section for further details.

To ensure that the university continues to obtain goods and services at the best value, the following methods of competitive bidding are required for all new contracts or non-contracted purchases.  If assistance is needed, it is recommended to engage the Procurement Department early in the bidding process. Note: Sponsored Project procurement thresholds are different from general SU procurement thresholds.

*Diverse Business Enterprise (“DBE”): “DBE” or “Diverse Business Enterprise” is a business that
identifies as and attests to being majority owned by Black, Indigenous, other POC, LGBTQIA+,
veteran, women, or socially and economically disadvantaged persons. Although the University
prefers in its contracting that such business enterprises be certified by the Washington OMWBE,
DBEs are not required to be certified by the OMWBE unless an anticipated expenditure is required to be competitively bid under the University’s Procurement Policies. In this situation, certification by entities other than OMWBE will be considered on a case-by-case basis. 

Cost sharing is any project cost that is not reimbursed by the sponsor to support the scope of work defined by the sponsored award.  Cost sharing, also known as “matching funds” or “in-kind support”, is funded by Seattle University or a third-party, which is generally a non-federal resource.

Cost-share requirements are determined in the proposal stage and if included in a proposal and subsequent award, cost-share will be held to the same standards as the sponsor funded award in regards to personnel, purchasing, prior approvals, tracking, reporting, and spending down. All committed cost sharing must be tracked and may require reporting.

If an error, unallowable cost, or cost overrun is discovered, the PI and Budget Manager must complete a standard Journal Entry form and an additional grant-specific  Cost Transfer Justification Form to remove the unallowable cost. The unallowable cost or cost overrun should be transferred to a departmental or divisional operating or unrestricted fund account. 

• Complete the JE to request the revision - each applicable budget manager (credited and debited) needs to sign
• Complete and attach the Cost Transfer Justification Form to document the purpose of this transfer 
• Submit both forms to the Grant Accountant in the Controller's Office
  • The Grant Accountant reviews for allowability. Please be specific on the cost transfer justification form.

JEs should only be used to correct errors and not as a mechanism to regularly shift expenses from a different account on to a sponsored project account. This is a highly discouraged situation as it can raise red flags during an audit.

Seattle University’s policy is to charge the federally negotiated indirect rate (42% of modified total direct costs) to all publicly-funded sponsored projects. Privately-funded grant indirect costs are charged at the accepted rate of the sponsor, as negotiated by the Director of the Office of Sponsored Projects at the time of the proposal submission.

Indirect costs include the facilities and administrative costs that are not easily assigned to specific projects such as physical building space, utilities, technological services, minor office supplies and printing, and administrative staff of the department and university, among other real costs. 

Purpose: to ensure your records match with the official institutional records. By tracking expenses and reconciling on a monthly basis, you can identify mistaken charges, anticipated charges that are missing from the university’s official record, or capture charges missed from your records.

To assist in the review of your expenses, OSP provides this budget tracking template for your use.

• Ongoing: Projects Accounting ties directly into our university accounting system but was designed specifically for projects. A key feature is that the project budget is based on the project's period, not the university's fiscal year. Use this module to check the financial health of your project(s) at any time.
• Monthly: At the end of each month's financial close (approximately 2-3 weeks after the end of each month), the Controller's Office will send an email to all Activity Managers announcing the close of the month. At this time, the Activity Manager must reconcile their records with the controller's monthly financial report provided in InformSU.
• Quarterly: After the end of each fiscal quarter while your sponsored project is active, the Grant Accountant will send a summary report of your financials comparing actuals to date with total budget, rate of spending, and project timeline complete (% of total award period already complete). This report must be signed by the sponsored project's PI/PD and budget manager certifying that the charges are correct.

The PI, with support from the Grant Management Specialist, is responsible for spending their sponsored project funds and associated cost share (if applicable) at the rate proposed in the project’s plan. Good communication and timely review of financial information by both the PI and Activity Manager will help avoid spending spikes, address potential audit questions, and facilitate close-out of the award.

Activity Managers should work with their PIs to develop a spending plan for a controlled spend of the award dollars to avoid a spike of spending toward the end of the award period due to inadequate financial planning. Spending spikes not only pose an audit risk, but often result in unallowable costs that require transfer off of the award.

Most sponsors request that a financial report be submitted annually (on or after the anniversary of the project start date) and a final financial report after the project end date. This report must be completed with financial data from the Grant Accountant (and oftentimes, must be submitted by her). Please consult with the Grant Accountant to ensure accurate financial data is submitted.