uconn

Storrs-UConn Health F&A

Because Storrs and UCH are two separate entities both from the standpoint of the state and for federal grants (and have different financial systems), this places us in a situation similar to the University of Maryland, University of Massachusetts and Cornell University. We used the Cornell model to develop guidelines to promote intercampus collaborations between Storrs and UCH and placed them on our website earlier this year. This has assisted researchers in understanding the procedures at the other campus and resolved issues that in the past have been a concern.

We currently have a global MOA between Storrs and UCH and create individual agreements for each project. They are simple and are put in place quickly.

Additionally the current practice is for the prime recipient to waive F&As on the first $25K of the sub-award if including them would diminish proposed direct costs.

In situations where amount of project cost funding is capped and the subrecipient’s F&As are included in the total direct costs, the subrecipient organization will not include its F&As in the budget. Once awarded, the prime recipient will share its F&As with the subrecipient proportionately to the awarded direct costs. This will be implemented for all future grants.

Technology Transfer FAQs

Protecting your IP

What is a patent?

A patent gives the holder the right to exclude others from making, using, selling, offering to sell and importing any patented invention. Note, however, that a patent does not provide the holder any affirmative right to practice a technology, since it may fall under a broader patent owned by others; instead, your patent only provides the right to exclude others from practicing it. Patent claims are the legal definition of an inventor’s protectable invention.

Is there a legal definition of an invention?

The United States patent law requires that an invention meet the following three criteria, in order to be eligible for patent protection:

  • Novelty: The invention must be demonstrably different from already available ideas, inventions or products (known as "prior art"). This does not mean that every aspect of an invention must be novel. For example, new uses of known processes, machines, compositions of matter and materials are patentable. Incremental improvements on known processes may also be patentable.
  • Usefulness: For an invention to be patentable, it must have some utility or application, or be an improvement over the existing products and/or technologies.
  • Non-obviousness: The invention cannot be obvious to a person of "ordinary skill" in the field. Non-obviousness usually is demonstrated by showing that practicing the invention yields surprising, unexpected results.

What is a copyright?

A copyright is a form of protection provided by the laws of the U.S. and other countries to the authors of "original works of authorship." This includes literary, dramatic, musical, and artistic and certain other intellectual works as well as computer software. This protection is available to both published and unpublished works. The Copyright Act usually gives the owner of copyright the exclusive right to conduct and authorize various acts, including reproduction, public performance and making derivative works. Copyright protection is automatically secured when a work is fixed into a tangible medium such as a book, software code, video, etc. In the United States, copyright protection lasts the lifetime of the author plus 70 years. In some instances, TCS registers copyrights, but generally not until the commercial product is ready for production and distribution/sale. All new software and source code should be disclosed as with any new invention and will be processed and managed by TCS.

How do I represent a copyright notice?

Although copyrightable works do not require a copyright notice, we do recommend that you use one. For works owned by UConn use the following notice: "© 20XX University of Connecticut. All rights reserved."

What is a trademark or service mark?

A trademark includes any word, name, symbol, device or combination that is used in commerce to identify and distinguish the goods of one manufacturer or seller from those manufactured or sold by others, and also to indicate the source of the goods. In short, a trademark is a brand name. A service mark is any word, name, symbol, device or combination that is used or intended to be used in commerce to identify and distinguish the services of one provider from those of others and to indicate the source of the services. It is not necessary to register a trademark or service mark to prevent others from infringing upon the trademark.

Trademarks generally become protected as soon as they are adopted by an organization and used in commerce (even before registration). With a federal trademark registration, the registrant is presumed to be entitled to use the trademark throughout the U.S. for goods or services for which the trademark is registered. UConn has trademark protection on items such as sports logos, mascots, emblems and images of university events.

Working with Industry

What is a Sponsored Research Agreement?

A university/industry research collaboration is formalized by a Sponsored Research Agreement (SRA). The sponsor and faculty member agree on the specifics of the work and a tentative budget. The final budget and all other aspects of the final contract are negotiated via the Sponsored Program Services (SPS) on the Storrs campus or the Office of Research and Sponsored Programs (ORSP) at the Health Center. The contract addresses a variety of issues including amount of funding, scope of work, IP rights, governing law, etc.

What are Licensing Agreements?

A license grants permission by the owner or controller of intellectual property to another party, under a formal agreement, for use of the intellectual property. License agreements describe the rights and responsibilities related to the use and exploitation of intellectual property developed at UConn. University license agreements usually stipulate that the licensee should diligently seek to bring the intellectual property into commercial use for the public good and provide a reasonable return to UConn. Licenses can be exclusive (only one company/group can make use of the technology during the license period) or non-exclusive (technology can be licensed to others without restriction)

A licensee is chosen based on its ability to commercialize the technology for the benefit of the general public. Sometimes an established company with experience in similar technologies and markets is the best choice. In other cases, the focus and intensity of a startup company is a better option. It is rare for UConn to have multiple potential licensees bidding on an invention.

For more information on Licensing Agreements, contact:

Gregory Gallo, Director of Technology Transfer
860.679.8774
gregory.gallo@uconn.edu

Can I share my new idea or invention with industry or other inventors outside of UConn?

Non-Disclosure Agreements (NDAs) or Confidential Disclosure Agreements (CDAs) are used to protect the confidentiality of an invention during evaluation by potential licensees. CDAs/NDAs also protect proprietary information of third parties that UConn researchers need to review in order to conduct research or to evaluate research opportunities. UConn enters into CDAs/NDAs for university proprietary information shared with someone outside of UConn. CDAs/NDAs can be prepared or reviewed and signed by the SPS or TCS.

Can I share and/or accept materials from industry or other researchers outside of UConn?

Yes, but the university must execute a Material Transfer Agreement (MTAs) in each case. MTAs are used for incoming and outgoing materials at UConn, especially for outgoing materials to industry, and are administered by TCS. These agreements describe the terms under which UConn researchers and outside researchers may share materials, typically for research or evaluation purposes. Intellectual property rights can be endangered if materials are used without a proper MTA. Material transfers going out of UConn must be accompanied by a formal agreement that addresses a variety of issues including definition of the materials, ownership, licensing rights, publication, etc. MTAs will be generated, reviewed and negotiated by the SPS or TCS.

Can I accept a contract from a company to provide non-research services that support their development?

Fee for Services Agreements (FSAs) are used in those cases where UConn may perform service-for-a-fee, which is essentially running previously developed tests on a sponsor’s materials, if such work is consistent with a department’s academic mission, and if UConn is uniquely qualified and positioned to do so. Such work is not research, and fee funds cannot be used to conduct research. The material and data provided, as well as those generated, may be proprietary to the sponsor. A pre-agreed Statement of Work is required, and to avoid problems, the Principle Investigator (PI) should not vary from it or any other relevant agreed upon conditions. FSAs are negotiated by the SPS, or the purchasing department of the Health Center.

Can my industry partner have rights to my IP without taking a license?

Yes through an Option Agreement. Option Agreements are entered into with third parties wishing to evaluate the technology prior to entering into a full license agreement. Option clauses within research agreements describe the conditions under which UConn preserves the opportunity for a third party to negotiate a license for intellectual property. Option clauses are often provided in SRAs to corporate research sponsors.

Awards

In addition to being the University’s authorized representative for grants, contracts and other agreements from government agencies, private industry, and non-profit foundations and the central point of coordination for sponsored projects, Sponsored Program Services administers grants and contracts on behalf of the University.

Activities include establishing new awards and budgets in the University’s accounting system (KFS) and assisting with pre-award coding requests, approving and processing re-budgets of expenditures, cost transfers, no-cost extensions and preparation of final financial reports.

Awards Management also provides guidance and consultation on issues such as applicable regulations, allowable costs, cost share and match requirements as well as monitor account activity for adherence to terms and conditions of awards and applicable policies and regulations.

All grant management policies at the University are derived from Federal, State and University policies and regulations such as Office of Management and Uniform Grant Guidance.

FCOI Glossary

PLEASE NOTE: 

  • Investigator is defined as “The principal investigator and any other person (regardless of title or position) who is responsible for the design, conduct or reporting of research or educational activities. This may include faculty and research staff (research associates and assistants, postdoctoral fellows, graduate students, visiting scientists engaged in research conducted at the University) as well as consultants.”
See below for additional FCOI terms and definitions:
Any corporation, partnership, sole proprietorship, firm, franchise, association, organization, holding company, joint stock company, receivership, business or real estate trust, or any other legal entity organized for profit or charitable purposes.
Any experiment in which a drug is administered or dispensed to, or used, involving one or more human subjects. An experiment here is any use of a drug, except for the use of a marketed drug in the course of medical practice.
Any experiment that involves a test article and one or more human subjects, and that either is subject to requirements for prior submission to the Food and Drug Administration under section 505(i) or 520(g) of the act, or is not subject to requirements for prior submission to the Food and Drug Administration under these sections of the act, but the results of which are intended to be submitted later to, or held for inspection by, the Food and Drug Administration as part of an application for a research or marketing permit. The term does not include experiments that are subject to the provisions of part 58 of the chapter, regarding non-clinical laboratory studies.
Any domestic or foreign, public or private, organization (excluding a Federal agency) from which an Investigator (and spouse and dependent children) receives remuneration or in which any person has an ownership or equity interest.
A situation in which significant financial interests in a business, or other personal considerations provided by a business, may compromise, or have the appearance of compromising, an Investigator’s professional judgment in conducting or reporting research, the results of which could affect the aforementioned business, either directly or indirectly. An FCOI exists when the University, through its designated official(s), reasonably determines that an Investigator’s Significant Financial Interest is related to a research project and could directly and significantly affect the design, conduct or reporting of the research.
A living individual about whom an Investigator conducting research obtains data through intervention or interaction with the individual, or identifiable private information.
An individual who is, or becomes, a participant in research, either as a recipient of the test article or as a control. A subject may be either a healthy human or a patient.
The Investigator’s spouse/domestic partner and dependent children.
Any domestic or foreign, public or private, entity or organization (excluding a Federal Agency) that is applying for or that receives NIH research funding.
An Investigator’s professional responsibilities on behalf of the University, which include research, teaching, and service as, e.g., outlined in the Policy on Faculty Professional Responsibilities
A product of the intellect that has commercial value, including copyrighted works, patents, business methods, and industrial processes.
The principal investigator and any other person (regardless of title or position) who is responsible for the design, conduct or reporting of research or educational activities. This may include faculty and research staff (research associates and assistants, postdoctoral fellows, graduate students, visiting scientists engaged in research conducted at the University) as well as consultants.
This is the first step for institutions in determining whether a financial conflict of interest exists. A significant financial interest is related to the research if an institution, through its designated official(s), reasonably determines that the significant financial interest could be affected by the funded research, or is in an entity whose financial interest could be affected by the research.
Salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value.
A systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge. Activities which meet this definition constitute research for purposes of this Policy, whether or not they are conducted or supported under a program which is considered research for other purposes.
An individual company, or any entity which takes responsibility for the initiation, management, and/or financing of a research project, but which does not actually conduct the investigation.

Post-Award Forms

Re-Budgeting Request Form

Used to request that the expenditure budget for a sponsored project account be revised to meet project needs.

 

No-Cost Extension Request Form

Used to request extra time to complete work on a sponsored project without additional funds being provided by the sponsor.

 

Cost Transfer Request Form

Used to request that a previously recorded expenditure be moved to or from a sponsored project account.

 

Pre-Award or Advance Account Request Form

Used to request that a KFS account be established prior to the start date of a project or receipt of the award notice.

Does Evaluation Require IRB Review?

Research studies involving human subjects require IRB review.  Evaluative studies and activities do not.  It is not always easy to distinguish between these two types of projects and projects frequently have elements of both.  Therefore, the decision about whether review is required should be made in concert with the IRB.

If you think that your project is limited to evaluative activities and therefore not subject to IRB oversight, please contact the IRB office at 6-8802 to discuss. 

The regulatory definition of research is defined as:

A systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge.

Evaluative studies are defined as:

Systematic collection of information about the activities, characteristics and outcomes of programs to make judgments about the program (or processes, products, systems, organizations, personnel, or policies), improve effectiveness, and/or inform decisions about future program development.

Below are elements that are common to evaluation and research projects.  This list is not intended to be comprehensive and not all elements are required in order for a project to be considered research or evaluation.  Rather, this list of elements can be used to assist faculty in determining whether an activity involves research requiring IRB review.

Common Elements

Evaluation

Research

Determines merit, worth, or value Strives to be value-free
Assessment of how well a process, product, or program is working Aims to produce new knowledge within a field(designed to develop or contribute…)
Focus on process, product, or program Focus on population (human subjects)
Designed to improve a process, product, or program and may include:

-needs assessment

-process, outcome, or impact evaluation

-cost-benefit or cost-effectiveness analyses

May be descriptive, relational, or causal
Designed to assess effectiveness or a process, product, or program Designed to be generalized to a population beyond those participating in the study or contribute broadly to knowledge or theory in a field of study (designed to develop or contribute to generalizable knowledge)
Assessment of program or product as it would exist regardless of the evaluation May include an experimental or non-standard intervention
Rarely subject to peer review Frequently submitted for peer review
Activity will rarely alter the timing or frequency of standard procedures Standard procedures or normal activities may be altered by an experimental intervention
Frequently, the entity in which the activity is taking place will also be the funding source May have external funding
Conducted within a setting of changing actors, priorities, resources, and timelines Controlled setting (interaction or intervention) or natural setting (observation which may or may not include interaction or intervention)

 

Informed by:

Coffman, J.  (2003).  Ask the Expert: Michael Scriven on the Differences Between Evaluation and Social Science Research.  The Evaluation Exchange, 9(4).  Retrieved January 8, 2012 from https://madvilletimes.com/

National Center for Justice Planning. (2012) Research and Evaluation Overview.  Retrieved on November 28, 2012 from https://www.ncja.org/

National Institutes of Health (2012). Evaluation Basics. Retrieved on November 28, 2012 from https://www.nigms.nih.gov/Research/Evaluation/

Oklahoma State University Institutional Review Board.  IRB Toolbox.  Program Evaluation: When is it Research? Retrieved on November 28, 2012 from https://compliance.vpr.okstate.edu/irb/irb-toolbox.aspx

Patton, M. Q. (1997). Utilization focused evaluation: The new century text. Thousand Oaks, CA: Sage.

Scriven, M. (1991). Evaluation thesaurus (4th ed.). Newbury Park, CA: Sage.

U.S. Government Accountability Office.  (2005).  Performance Measurement and Evaluation.  Retrieved January 8, 2012 from https://www.gao.gov/special.pubs/gg98026.pdf

Source material for this policy guidance was provided by Oregon State University. The UConn IRB gratefully acknowledges this support.

Back to Researcher’s Guide

Pre-Award Or Advance Account Request

  • If you are filling out the form on behalf of someone else, enter your contact information here.
  • Award Information

  • MM slash DD slash YYYY
  • Select your grant manager team. Refer to the list below.
  • Team 1 - K. Jabarkhail, B. Dauphinais, S. Corbin
    Team 2 - M. Niewinski, L. Abell, C. Wells, S. Warren
    Team 3 - K. Jabarkhail, J. McNeal, D. Ives, M. Niewinski
    Team 4 - D. Parciasepe, C. Rodgers, S. Parker
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      If so, please provide documentation to the SPS office.
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    Rebudget Request

    Read the Rebudget FAQ Sheet to get help when filling out this form.

    Fields marked with an asterisk (*) are required.

    • Principal Investigator Information

    • Administrative Contact Information

      In case additional information is needed. If you are submitting this form on behalf of the PI, please put your contact information here.
    • Select your grant manager team. Refer to the list below.
    • Team 1 -K. Jabarkhail, B. Dauphinais, S. Corbin
      Team 2 - M. Niewinski, L. Abell, C. Wells, S. Warren
      Team 3 - K. Jabarkhail, J. McNeal, D. Ives, M. Niewinski
      Team 4 - D. Parciasepe, C. Rodgers, S. Parker
      Research Excellence Program / Scholarship Facilitation Fund - Matthew Mroz
    • Transaction Information

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    No Cost Extension Request

    Cost Transfer Request Form

    IP Policy

    In addition to publications, presentations, and graduate theses, which communicate research findings to scientific colleagues throughout the world, research may also result in an invention. Inventions and their commercialization have always been a significant component of this country’s economic growth. Technology is critical to our international competitiveness and economic health. As a result, a large number of state and federal laws have been developed to facilitate this process and increase the rate at which valuable inventions move from the laboratory into the marketplace. The policies below govern this process at the University of Connecticut.

    Policies Regarding Research Collaborations with Industrial Partners and Technology Transfer

    OVPR Staff Resources

    Welcome to the OVPR Staff Resources Page!

    If you are looking for information that cannot be found here, please reach out to us at ovprhr@uconn.edu for assistance.

    The OVPR Operations Team provides administrative, financial and technical staff and programmatic support across all UConn and UConn Health locations. We are the “people-support” people of the OVPR!

    Check back frequently for announcements and current information.

    OVPR Operations Team

    Julie Schwager, Associate Vice President for Research Finance / Executive Director of Operations

    @OVPR HR Operations

    Computer and Technical Support

    @Research Finance

    Official Info and Action Items for OVPR Staff:  OVPR Minute

    New Resource(s) / Recently Added

    Wednesdays at One – OVPR HR Open Office HourNew and current OVPR staff and supervisors are invited to join the OVPR HR Team weekly for an overview of time cards, benefits, and open Q & A (please email ovprhr@uconn.edu if you have difficulties connecting).

    W@1 Schedule

    Useful Information and Links for OVPR Staff

    FAQ “Quick Links” for OVPR Staff

    OVPR Unit Administrative Contacts

    OVPR Administrative Calendar

    OVPR Forms / Documents

    Payroll Processing Information

    Core-CT Time Cards (Storrs & Regional Campuses)

    UConn Health Payroll Information

    2025 State Holidays and Check Dates (Calendar)

    Holiday Information for OVPR Staff

    Other

    Overview of The Office of the Vice President for Research (6 minutes)

    Recruitment Poster:  Careers In Research Administration

    OVPR NEO Presentation and Handout

    Important for Members of AAUPGuidance in Matters Pertaining to Merit, Workload, ByLaws, and Promotion and Tenure for OVPR Non-Tenure-Track and In-Residence Faculty Positions

    Policies, Procedures & Guidance

    Subrecipient Monitoring

    Project Risk Assessment

    Before executing a subrecipient agreement, and every two years thereafter, the subrecipient must complete and submit a Subrecipient Profile Questionnaire, which allows the University to identify project specific risks. Where the assessment reveals a high potential for risk, Sponsored Program Services (SPS) will propose a risk mitigation strategy before proceeding with the subaward.  The risk assessment takes into account several factors, including the following:

    • Type of subrecipient organization (for-profit/not-for-profit/small business/corporation/ foreign/domestic)
    • Whether the subrecipient is subject to the Single Audit requirements.  Subrecipients not subject to Single Audit requirements must provide more information regarding their financial status and systems as part of the Subrecipient Profile Questionnaire
    • Subaward value relative to the prime award
    • University’s prior relationship with the subrecipient
    • Organizational and individual conflict of interest
    • Necessary IRB and/or IACUC protocols

    Post-Award Subrecipient Monitoring

    The University is responsible for monitoring the activities of subrecipients to ensure that awarded funds are used for authorized purposes and that performance goals are achieved.

    • At least annually, SPS will review subrecipient’s financial stability, financial processes, and controls as follows:
      •  Subrecipients subject to Uniform Guidance (UG) that expend $750,000 or more of federal funds annually are subject to Single Audit requirements.  Annual Single Audit certifications are retrieved from the Federal Audit Clearinghouse.  If the Single Audit is not available from the Federal Audit Clearinghouse, SPS will be request Audit Certification directly from the Subrecipient.  In the event of an unfavorable audit certification, SPS will confirm that the subrecipient has taken appropriate and timely corrective action(s)
      • Subrecipients not subject to Single Audit requirements must provide annual audited financial statements
    • SPS will review the audit documentation and determine whether or not the Subrecipient’s risk designation requires reevaluation

    Federal Funding Accountability and Transparency Act (FFATA) Reporting

    As of October 1, 2010, all Federal grants of $30,000 and over are subject to the Federal Funding Accountability and Transparency Act (FFATA). FFATA requires UConn to report any subawards executed in the previous month that exceed $30,000, where UConn is the prime recipient. SPS staff use the FFATA Subaward Reporting System (FSRS) to enter, submit, and update the required FFATA reporting, which must be submitted by the end of the month following the month of full execution of the initial agreement or any subsequent amendment resulting in a subaward value of greater than $30,000.

    Progress Monitoring, Technical Reports and Deliverables

    • SPS, the responsible University PI, and department grant administrators will jointly determine the frequency and scope of departmental monitoring procedures. A “risk-based” approach to subrecipient monitoring is recommended with the frequency and intensity of monitoring driven by the terms of the prime award and the criteria identified in the section of this procedure titled Subrecipient Pre-Qualification Review.
    • PIs will monitor the progress of subrecipient work scope at least on a quarterly basis
    • Options for review include informal progress reports via phone conversations, e-mail communications, or face-to-face discussions, formal technical reports or other deliverables specified in the agreement required and due on specific dates. Subrecipient invoices will be submitted to the University PI
    • Subrecipient is required to submit invoices adhering to the following criteria:
      • Expenditures are reported for current period and cumulative period
      • Expenditures are itemized by cost category
      • Cost share and/or match is reported on each invoice
      • Invoice must also include the following:
        • Subrecipient’s name and address
        • Subaward Agreement Number and University account number
        • Project period and period of invoice
        • Invoice number and date prepared
        • Subrecipient contact person with respect to the invoice
        • Certification on each invoice as to the truth and accuracy of the invoice
      • Final Invoice must be submitted by subrecipient within forty-five (45) days of end date
    • PI will review and approve invoices from subrecipients to ensure that:
      • Expenditures are consistent with the proposed budget
      • Costs are incurred within the period of performance and are allowable
      • Expenses are aligned with technical progress
      • Cost sharing is appropriately reflected if required
    • The PI must sign the invoice to indicate that review has been completed and that the invoice has been approved for payment.

    Submitting Invoices for Payment

    The Principal Investigator must approve invoices for payment. This task may not be delegated.

    Resolving Invoice Issues

    • If PI identifies a concern with subrecipient performance, the PI will request clarification from the subrecipient PI.
    • If department grant administrators identify any unusual, apparently excessive, or potentially unallowable charges invoiced by a subrecipient and if the explanations from the subrecipient are insufficient to render a prudent judgment on the allowability of the cost, the department grant administrator shall refer the matter to SPS for resolution with the subrecipient’s institutional authorities.
    • When SPS is satisfied that the issues are resolved, they will notify the department and PI to proceed with approval for payment. Invoices will not be approved for payment until all issues or concerns have been resolved.

    Closeout of Subawards

    OVPR SPS, in collaboration with department administrators and/or PI, will begin subaward closeout actions immediately following conclusion of the subaward period of performance. Subawards will be processed for closeout and formally closed within a 60-day time period, unless SPS grants the department an extension. A subaward may not be formally closed until all of the following closeout requirements have been met:

    • Final review of costs charged to the University and final close-out of all commitments, accrued costs, or payables.
    • Receipt of final invoice from subrecipient and Subrecipient Release and Certification Form (Attachment C)
    • Receipt of all required deliverables as specified in the subaward, patent/invention documentation, and equipment reports. Final verification of technical completion will be indicated by the PI’s signature and date on the final invoice.

    Reports

    Technical Reports

    Principal Investigators are responsible for preparing and submitting both interim and final technical reports, which typically include a description of the work performed, results of the work and any related publications resulting from the work. The SPS should be copied on the cover letter accompanying the interim and final technical report.

    Financial Reports

    Preparation of Financial Reports is the responsibility of the OVPR SPS. These reports are generally due within 90 days of the award expiration on federal awards; the deadline may be even shorter for state and private awards. Inability or failure to submit reports within the stipulated time frame can result in the suspension of funding and/or a delay in the release of future funding. All expenditures related to the project must be processed, open encumbrances closed, cost sharing verified, and the account(s) reviewed for errors or necessary changes in order to prepare the final financial report. The following policies are to be followed to ensure that the University of Connecticut is operating in compliance with sponsor terms and Federal policies such as OMB Uniform Grant Guidance and Cost Accounting Standards and to ensure that Sponsored Program Services is able to prepare an accurate and timely final financial report for submission to the sponsoring agency as well as close the account in the University’s accounting system, Kuali Financial System (KFS).

    OVPR SPS will prepare and send to the Principal Investigator (PI) a draft report of final financial expenditures. There may be several items to which the PI is asked to respond. These include review of overexpenditures, expenditures after the end date, documentation of cost sharing, and identification of any charges not yet recorded in the University’s financial system (KFS). It is essential that these drafts are reviewed and returned within the time frame stated on the draft from OVPR SPS. In order to comply with sponsor reporting requirements, OVPR SPS will prepare finals based on the draft if the PI does not respond within the allotted time. Any unallowable expenditure, as well as any expenditure that remains unrecorded and therefore unbilled, will then become the responsibility of the PI and his/her Department Head or Dean.