Financial Policies

To establish responsibility for monitoring subrecipients receiving federal funds but not subject to the Office of Management and Budget’s (OMB) Uniform Guidance single audit or program-specific audit (2 C.F.R. Part 200.501)

To establish the criteria permitting individuals to fulfill the role of Principal Investigator or co-Principal Investigator on a sponsored project

To ensure that the revised final financial reports are submitted so as to mitigate any financial loss to the University or return of funds with interest to the sponsor.

To establish guidelines for the charging and approval of expenditures on awards from non-federal sponsors which do not reimburse the University at the approved Facility and Administrative cost rate.

To define the requirements for faculty having appointments less than 12 (twelve) months who choose to work and receive compensation from a sponsored project during the months of June, July and/or August.

To establish the requirement for individuals who carryout functions related to sponsored projects administration and identifies the responsible individual who will determine these individuals.

To ensure that agreements for research and other sponsored projects are reviewed for potential tax consequences.

The U.S. government has adopted a policy prohibiting human trafficking, sex trafficking, forced labor, and trafficking-related activities.  As a recipient of federal funds from grants, cooperative agreements, and contracts (collectively, “awards”), the University of Pennsylvania is obligated to inform its employees, agents, independent contractors and subrecipients performing awards, regarding the U.S. government’s policy.  The University of Pennsylvania opposes human trafficking, sex trafficking, and forced labor, which are inherently harmful and contrary to the University’s core values, and which may violate applicable foreign, U.S., state, and/or local laws.

To establish responsibility for the retirement of equipment on sponsored projects in compliance with sponsor terms and conditions.

To comply with the federal Office of Management and Budget’s Uniform Administrative Requirements (UG), C.F.R. 200 and other sponsor requirements to ensure that unallowable costs related to salary are not charged to federal awards. The UG Part 405 states that costs charged to federal awards must directly benefit the award to which they are charged. UG Part 460 further specifically states that the costs of proposal preparation should be treated as Facilities and Administrative (indirect) costs.