Rebudgeting

After an award has been set-up, the Principal Investigator may determine that the approved budget allocations among the budget cost categories (e.g., personnel, equipment, other direct costs, etc.) will not meet the spending needs of the project.  In such instances, the Principal Investigator may, depending on the particular sponsor’s requirements and the specific award terms, need to formally seek prior approval for the reallocation of funds (i.e., request to rebudget between various cost categories) to support advancement of the project.

• If prior approval from the sponsor is required, the PI (or the PI’s department) is responsible for preparing a rebudgeting request for SPA’s submission to the applicable sponsor along with sufficient justification for such request.  Upon receipt of sponsor approval, SPA will process a Campus Award Notice (CAN) through Kuali Award.
• If rebudgeting does not require sponsor approval, SPA’s involvement is not required nor will a CAN be processed through Kuali Award. However, the PI (or the PI’s department) must process the budget reallocations in POETAF within Oracle Project Portfolio Management (PPM).
• If the terms of the award do not indicate whether rebudgeting is permitted without prior approval or you are unsure of the particular sponsor’s requirements, please contact your Contract & Grant Officer for assistance.

Requests for No Cost Time Extensions to an Award

Should the PI determine that additional time is required to complete the scope of work and/or reporting requirements of an award, then a request for a No Cost Time Extension (NCE) should be timely submitted, through RED to the sponsor, in accordance with sponsor policy. Please contact your Contract & Grant Officer for assistance.

Research Projects Operating Abroad

The UCOP Office of Risk Services has arranged foreign liability insurance for the University's operations outside the USA.  The primary goals of purchasing this centrally controlled insurance program are to protect the University and adhere to local insurance laws, while allowing the University faculty and staff to engage in research and educational endeavors abroad with minimal insurance procurement administration and costs.

Before starting any project abroad, there are several items that should be to taken into consideration:

Foreign General Liability

• Are you signing a lease for office or research space and being required to provide evidence of insurance coverage?
• Are you purchasing any office or research space?
• Are you entering into any contracts with foreign government agencies or entities?

If you answer "Yes" to any of the above, UC may be required to procure a general liability policy in the country where you are operating, in order to be compliant with local insurance laws and regulations.  UCOP Risk Services has partnered with a global insurance carrier who has the capabilities to issue a general liability policy in most countries abroad, thereby facilitating and minimizing the administration for UC.

• Are you conducting any clinical trials abroad and being required to provide the insurance coverage for the trial?

If you answer "Yes", UC may be required to procure a Human Clinical Trial liability policy to adhere to the insurance laws and regulations of the country where you are conducting the trial.  Each country has its own compulsory liability insurance requirements for Human Clinical Trials.

Foreign Automobile Liability

• Are you acquiring a long-term leased automobile or purchasing an automobile?

If you answer "Yes", you will need to either purchase the compulsory automobile liability insurance from the automobile leasing company or from a local insurance market.  Automobile liability insurance is compulsory in almost every country and UC and/or you could face severe penalties and fines if you do not purchase this insurance coverage.

Foreign Workers' Compensation & Foreign Employer's Liability

• Are you hiring any local nationals to work for you as an employee?

If you answer "Yes", UCOP Risk Services and our insurance broker, Marsh Risk & Insurance Services, will need to evaluate whether the workers' compensation and employer's liability benefits in the country where you are hiring the employee are part of a government social scheme or require the purchase of an insurance policy.  Workers' compensation is compulsory insurance coverage in most countries, and employer's liability insurance is required in several countries.

• Are you hiring anyone as an "independent contractor"?

If you answer "Yes", you will need to use the same methodology employed in the USA to evaluate the tasks of the "independent contractor" in establish whether this person would be deemed an employee.  If you are unsure of this methodology, you will need to contact UCOP Risk Services.

If you have any questions regarding this coverage or need any assistance regarding insurance issues related to operating abroad, please contact UCR Risk Management at (951) 827-8221, or you may contact UCOP Risk Services directly by calling:  510-987-9832.

Post-Award Audits

A sponsored project awarded and accepted by the University may contain a provision which permits the sponsor, or the sponsor's representative, to access our facilities for the purpose of auditing the performance of that particular award. Should the sponsor request to perform a post-award audit, the external audit coordinator for the campus should be contacted to coordinate the audit.

Annual Financial Audits

Annual financial audits for the University of California are conducted on a consolidated basis including all campus locations. The audited financial statements are included in the University's Annual Financial Reports, which are available at: http://www.ucop.edu/financial-accounting/.

A-133 Audit Reports

A sponsored project funded with federal monies may contain a provision requesting a copy of the University's annual audit report, in accordance with the requirement of OMB Circular A-133. As with the financial audits, the A-133 audits are conducted on a consolidated basis including all campus locations. The University's fiscal year ends June 30, and the A-133 audit report is issued by the end of March in the following year. A copy of the A-133 audit is submitted to the University's cognizant federal agency for A-133, the U.S. Department of Health and Human Services, and also to the Federal Audit Clearinghouse operated by the Bureau of the Census. The latest available audit information can be found at http://ucop.edu/financial-accounting/financial-reports/a-133-audit-reports.html. Further information from A-133 audits is accessible through the Federal Audit Clearinghouse web site at https://harvester.census.gov/facweb/ searching by organization name "UNIVERSITY OF CALIFORNIA".

All requests for a copy of UCR's A-133 audit report should be directed to the Office of Research and Economic Development.

Guidelines for Fulfilling and Documenting Cost Sharing

Background

As a recipient of Federal funds, UCR is required to account for and report cost sharing in a manner consistent and in accordance with federal regulations.

Cost sharing becomes a legal obligation that must be fulfilled when UCR submits a proposal that contains a cost sharing commitment and the sponsor makes an award in response to that proposal. The same is true if UCR accepts an award that contains a cost sharing requirement. Failure to fulfill the cost sharing commitment may result in the sponsor reducing available project funds. Therefore, it is important to understand the risks associated with cost sharing and how to document the fulfillment of cost sharing commitments.

Definitions

• Cost sharing is any portion of the total costs of a project or program not borne by the sponsor. Cost sharing typically takes the form of in-kind resources (e.g., contributed project personnel effort) or cash.
• Cost sharing commitment means any cost sharing that is offered and quantified anywhere in a proposal.
• Cost sharing contribution means the use or expenditure of any in-kind resource or cash to fulfill a cost sharing commitment in the course of performing the scope of work under and extramural award.
• Third party cost sharing means cost sharing commitments or contributions made by an organization other than UCR or the sponsor.

Fulfilling Cost Sharing Commitments

UCR assumes certain obligations when it accepts an award involving a cost sharing commitment, including the obligation to certify and report to the sponsor the aggregate dollar value of cost sharing contributions. In fulfilling cost sharing commitments, principal investigators, department administrators, chairs, directors, deans and vice chancellors must exercise care to ensure that costs identified and tracked as cost sharing contributions meet the following eligibility criteria:

• the costs must be able to be documented and verified based on UCR's records;
• the costs must not be included as a cost sharing commitment related to any other project or program (i.e., the same costs may not be proposed as cost sharing for two or more projects);
• the costs may not be committed, or contributed, from another extramural award, except where specifically authorized by Federal statute or the sponsor (e.g., costs incurred under a NIH grant may not be proposed or accounted for as a cost sharing contribution under a NSF grant or any other federal or non-federal grant);
• the costs must be necessary and directly related to the project objectives;
• the costs must be incurred during the same performance period as the award supporting the project;
• the costs must be allowable and allocable under federal cost principles (OMB Circular A-21) and the terms of the sponsored agreement; and
• the costs must be identified in the approved budget or award (either directly or incorporated by reference) when required by the sponsor.

Principal investigators should notify the Office of Research as soon as they reasonably know that the cost sharing commitment for a particular project may not, or will not, be fulfilled. This is includes those situations when a principal investigator transfers to another institution during the performance period of a project, as the sponsor may hold UCR responsible for fulfilling all or a proportionate share of any cost sharing commitment associated with the project.

Documenting Cost Sharing

Cost sharing contributions and third-party contributions are subject to audit. Thus, department business offices and/or principal investigators may be requested to provide auditors with supporting documentation and records that support and document the cost sharing contributions tracked and ultimately reported to sponsors. Cost sharing records and supporting documents, such as paid invoices, travel vouchers and receipts should be retained in accordance with the University Records Management Disposition Schedules. In addition, effort contributed by project personnel should be recorded and certified on a Personnel Activity Report. If third-party contributions (other than cost sharing provided by subrecipients under UCR's prime awards) will be used to fulfill a cost sharing commitment, source documents supporting the dollar amount of third party cost sharing should also be retained.

Certifying and Reporting Cost Sharing

Cost sharing contributions must be certified and reported to the sponsor. The Extramural Funds Unit of the UCR Accounting Services Department is responsible for coordinating the certification and reporting of cost sharing to sponsors. When UCR certifies a cost sharing report, it is assuring the sponsor that:

• the costs recorded on the report are true and accurate;
• the costs were contributed to the identified project during the reporting period; and
• the costs have not been, and will not be, used as cost sharing contributions on any other projects or for any other periods relating to the identified project.