Compliance + Pre-Audit Responsibilities
Responsibilities of the college
Certain compliance and pre-audit functions are the responsibility of the individual colleges and schools as follows:
- Provide necessary training within the college for each employee.
- Ensure consistency in budgeting of direct costs vs. facilities and administrative (F&A) costs (pre-award phase).
- Ensure consistency in charging of direct vs. F&A costs (pre-audit function).
- Ensure budgets submitted to sponsoring agencies are in compliance with all applicable sponsor regulations.
- Obtain and retain appropriate Cost Accounting Standards “unlike circumstance” written justification. Provide these justifications, when requested, to internal and external auditors.
- Conduct pre-audit reviews of all charges to sponsored awards to ensure that expenditures and subsequent adjustments to expenditures are reasonable, allowable, allocable, timely and applied consistently in like circumstances.
- Obtain and retain appropriate support documentation for financial transactions. This includes cost sharing documentation as well.
- Ensure prior approvals for expenditures and activities are obtained when required. Requests for prior approval should contain adequate justification to determine the impact of the request on the technical aspects of the project as well as its reasonableness in terms of costs. Prior approval requirements for each sponsored project can be determined by reviewing the following documents:
- “Regulatory Checklist” for each Federal agency
- Award document and any regulations cited therein
- Ensure compliance with cost sharing commitments on sponsored projects. Documentation of all cost sharing should be in an acceptable format and be submitted in a timely manner when required. Maintenance of supporting documentation is required.
- Establish internal procedures to ensure the timely processing of personnel actions and retroactive payroll adjustments which affect sponsored awards.
- Monitor and maintain the committed level of effort on sponsored projects.
- Ensure the conscientious completion, certification, and timely return of effort reports. The coordination of retroactive labor adjustments is required within 90 days after the payroll period.
- Prevent budget overdrafts.
- Ensure all adjustments to expenditures are performed timely.
- Review subcontractor costs for reasonableness and compliance with prior approval and cost sharing requirements before processing subcontractor invoices for payment.
- Perform monthly reviews of charges to sponsored awards (Ledger 5 accounts) appearing on WRS expenditure reports to ensure that all charges were pre-audited. Determine that no unallowable or unrelated costs were charged to the project in error. Complete online close-out process and route according to stated due date.
- Process closeout adjustments prior to routing online closeout.
- Ensure all technical reports are completed and submitted on a timely basis.
The Office of Contracts and Grants, under the direction of the Associate Vice Chancellor of Finance and Resource Management, is responsible to the University and to the funding agencies for the financial and regulatory administration of all contracts and grants awarded to North Carolina State University. This responsibility includes, but is not limited to:
- Establish, communicate and promote policies and procedures consistent with federal, state and sponsor regulations.
- Provide assistance with proposal budget preparation if requested by the college.
- Determine the propriety and reasonableness of costs.
- Exercise budgetary control of contracts and grants funds.
- Prepare and submit financial reports and invoices.
- Make timely deposits of contract and grant receipts from sponsors and follow up with sponsors on delinquent payments.
- Process prior approval requests when sponsor has delegated the authority or submit requests to other University offices or the sponsor when necessary.
- Submit final financial reports, equipment inventories, and intangible asset disclosure statements to funding agencies.
- Maintain an effective, auditable effort reporting system.
- Monitor over 90-day payroll reallocation transactions.
- Develop and negotiate the University’s F&A cost rates.
- Review and approve all special service facility rates affecting sponsored projects.
- Coordinate formal audits or interim reviews of contracts and grants by sponsoring agencies.
- Provide support and guidance to college business offices for the effective administration and financial management of contracts and grants.
- Perform annual subrecipient monitoring in accordance with OMB Circular A-133 and NCSU procedures.
- Maintain the University’s Cost Accounting Standards Disclosure Statement and submit changes to cost accounting practices as necessary.