Sponsored Programs at Penn Rules governing the conduct of sponsored projects part 1: federal regulations

Conduct of Sponsored Projects The conduct of sponsored projects must comply with: Federal state and local laws Terms and conditions of the award For awards with federal funding, or where the original source of the funding is federal, the Uniform Guidance (2 C.F.R. 200) Applicable Penn policies This module will focus on the Uniform Guidance (UG)

Overview of the UG Subpart A: Definitions Subpart B: General provisions Subpart C: Pre-Federal Award requirements Subpart D: Post Award requirements Subpart E: Cost principles Subpart F: Audit requirements Subparts D and E are of central importance to Penn research administrators and Investigators managing federal awards.

Subpart C Pre-award key provisions Agreement types (grant, contract, cooperative agreement Method of Costing Change in PI Notice of funding opportunities Merit review process Risk review Application requirements Certifications and representations as required by federal statutes Information contained in the award Public access to award information Suspension and debarment

Subpart D key Post-award provisions Change of scope Revision of budgets Carryover Procurement Subrecipient monitoring Cost sharing Program Income Reporting Closeout Record retention

Sponsor prior approval Generally under the UG, sponsor prior approval is required when an ongoing project has: A change of scope A change of PI or key personnel, including significant change in effort Large change in budget allocation Fixed price subawards In addition, it is always necessary to review the award terms and conditions for additional requirements of sponsor prior approval, such as for travel expenses or the purchase of equipment.

Subpart E Cost principles Standards for allowability of costs Reasonable Are costs prudent and necessary to accomplish project aims? Allocable Does the cost benefit only this project, or can it be readily apportioned to the projects that benefit? Consistently treated Are similar costs incurred for the same purpose treated in the same way (as direct or indirect costs)? Direct and indirect (F&A) costs Direct: specifically identifiable with activity F&A: incurred for common or joint objectives

Unallowable costs The following costs are generally unallowable on federal awards: Entertainment Alcohol Bad debt Fines, penalties and other settlements Honoraria Lobbying or Fundraising costs

Additional UG general cost principles Committed Cost Share (cash, third party and in kind) must be Verifiable from recipient records Not used as a contribution in more than one federal program Necessary and reasonable for the project Program income must be tracked and used as defined by the sponsor in one of the following ways: Additive Deductive Cost share