If you are the recipient of a U.S. federally funded award, you must adhere to specific compliance requirements.
U.S. federally funded awards include all awards received directly from U.S. government agencies (including NIH, CDC and the National Science Foundation), as well as all funding from U.S. government agencies which is passed on through intermediate entities (e.g., NIH funding passed on by the University of Washington).
For NIH policies that cover eligibility of expenditures, audit requirements, administrative requirements, etc., please review the NIH Grants Policy Statement.
Your award is subject to an annual OMB Circular A-133 audit. OMB Circular A-133 is a document issued by the U.S. government which sets forth standards for obtaining consistency and uniformity among federal agencies for the audit of non-federal organizations expending federal awards.
Federal agencies apply the provisions of the sections of this Circular to non-federal entities, whether they are recipients expending federal awards received directly from U.S. federal awarding agencies, or are sub-recipients expending federal awards received from a pass-through entity (a recipient or another sub-recipient).
The OMB Circular A-133 audit follows U.S. guidelines and is more stringent than Canadian audits on grants. External auditors paid for by the University will perform this audit. In addition, Research and Trust Accounting (RTA) will carry out spot audits throughout the year.
Time and Effort Reporting
The annual audit requires adequate time and effort reporting. This requires that salaries charged to research PGs match the effort expended on the award. Please ensure a review of salary charges is done from time to time, throughout the year, to ensure a proper matching of time and effort.
If an employee does not spend time on the research project equal to the percentage of their time charged to the PG, a Change of Appointment form should be sent to payroll to reduce the cost to the PG in accordance with time spent on the work. Twice a year, RTA will confirm that employee time charged to these awards is appropriate. The external auditors will also test this area.
Research Performance Progress Report (RPPR):
NIH began implementing the Federal-wide RPPR in the Fall of 2012. NIH now requires use of the RPPR module in eRA Commons to submit ALL annual progress reports.
One significant change that comes with the RPPR process is automatic screening for compliance with the NIH public access policy. This policy requires that manuscripts resulting from NIH funding be deposited with the PubMed Central archive. Researcher will need to use My NCBI to enter papers onto progress reports. Publications and manuscripts listed in the progress report and falling under the NIH Public Access policy must include the PubMed Central reference number. NIH will not award non-competing continuation awards when the RPPR publications are not in compliance with the Public Access Policy.
Journal transfers of costs into U.S. federally funded PGs from other PGs must identify the original invoice or expense source, and the expenses in question must be related to the research in the U.S. federally funded PG. Entries to simply transfer a deficit balance from another PG are not permitted.
Please review the list of ineligible expenses for NIH grants on the website: https://grants.nih.gov/grants/policy/nihgps/HTML5/section_7/7.9_allowability_of_costs_activities.htm. This listing does not necessarily apply to all U.S. federally funded awards. Please check the individual award agreement and/or agency policy that may define specific areas of ineligible expenditure.
Please also review the UBC guidelines for processing and recording participant support costs.
Any equipment purchased with U.S. federal monies needs to be tracked and itemized with the following details:
(See 2 CFR Ch. II § 215.34)
(1) Equipment records shall be maintained accurately and shall include the following information.
(i) A description of the equipment.
(ii) Manufacturer’s serial number, model number, Federal stock number, national stock number, or other identification number.
(iii) Source of the equipment, including the award number.
(iv) Whether title vests in the recipient or the Federal Government.
(v) Acquisition date (or date received, if the equipment was furnished by the Federal Government) and cost.
(vi) Information from which one can calculate the percentage of Federal participation in the cost of the equipment (not applicable to equipment furnished by the Federal Government).
(vii) Location and condition of the equipment and the date the information was reported.
(viii) Unit acquisition cost.
(ix) Ultimate disposition data, including date of disposal and sales price or the method used to determine current fair market value where a recipient compensates the Federal awarding agency for its share.
Physical counts will be conducted every two years and compared to the equipment listing.
RTA will also conduct annual confirmation of equipment purchases with the researcher. No assets may be given away, re-sold, or disposed of without obtaining proper independent confirmation of the resale value, and payment of this resale value. Failing to keep an asset available for inspection constitutes misuse of sponsor funds.
U.S. federal funds that are unspent at the award end date must be returned to the sponsor. RTA will monitor and contact researchers as end dates approach, but it remains the researcher’s responsibility to cease spending, or to initiate an extension.
NIH offers a maximum extension of up to one year after the expiry of your grant term provided that this is requested prior to the end date; please contact the Office of Research Services to invoke this extension.
For any directly funded U.S. federal awards that are governed by a contract or an agreement, please contact the University-Industry Liaison Office to seek an extension. For indirectly funded awards (e.g., funding from another university), an extension should be requested from the sponsoring institution, and confirmation of the extension date should be sent to the University-Industry Liaison Office. A new Research Project Budget will be issued to extend the end-date if the extension is approved.
So that over-expenditures are not assumed, in accordance with UBC Policy #90 Section 1.5, “Where a Researcher anticipates a renewal or other source of funding beyond the designated “end date” of the [U.S. federally funded] PG, the Researcher shall notify [RTA and their representative from the Office of Research Services or the University-Industry Liaison Office] prior to such end date.”
The researcher and their unit will bear the responsibility for any over-expenditures or costs arising when an extension is not applied for or granted.
All overhead is recovered by UBC, and a portion is returned to the faculty and/or facility where the research PG resides. Agency-specific overhead rates are listed on the VP Research & Innovation website.
Unless specifically requested, researchers should include appropriate overhead in their charge-out rates, their project costs, etc. In the case of NIH budgets, all budgets should state UBC’s 8% Facilities and Administrative Costs as a separate line item. This is always the case, even when UBC is not the lead institution.
For more information, visit NIH Facilities and Administrative Costs.
Closeout of an NIH award is the process by which NIH determines that all applicable administrative actions and all required work of an award have been completed by the researcher and NIH. Beginning October 1, 2014 NIH updated its closeout process based on new HHS closeout policies. Failure to submit timely and accurate final reports may affect future funding to the organization.
Researchers must ensure all applicable closeout reports are submitted no later than 120 days after the project end date as follows:
- Final Federal Financial Report (except for Fellowships): to be prepared and submitted by RTA
- Final Progress Report (except for Fellowships for which the Termination Notice will continue to serve as the Final Progress Report): to be prepared and submitted by researcher
- Final Invention Statement and Certification (except for Training grants, Fellowships, and certain other programs—e.g., activity codes C06, R13, R25, S10) : to be prepared by researcher and approved by UILO. Final submission will be handled by ORS.
- Termination Notice (PHS 416-7) This form is required for Fellowships and Training grants. It summarizes the information that must be supplied by Ruth L. Kirschstein National Research Service Award (NRSA) recipients on termination of their award and for a limited period thereafter. It must be submitted within 90 days of the fellow or trainee's appointment.
Publication Under NIH Awards - NIH Public Access Policy
NIH requires that articles supported by NIH-funded research be included in PubMed Central, the NIH digital archive of full-text, peer-reviewed journal articles. Its content is publicly accessible, free, and integrated with other databases. Please visit the NIH Public Access Policy for more information.