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

2. 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)

3. 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.

4. 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

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

6. 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.

7. 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

8. 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

9. 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