Financial Policies

Policies related to the financial operation of the University of Pennsylvania

2100 – Sponsored Projects
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Last Reviewed June 2023

2131 – Compliance With Subrecipient Standards of OMB Uniform Guidance

To establish responsibility for compliance with the Office of Management and Uniform Guidance 2 C.F.R. Part 200.330-337 (as it relates to the University’s responsibilities in making awards to subrecipients).

2100 – Sponsored Projects

Research Services

Last Reviewed June 2023

2132 – Record Retention

To establish responsibility for the retention of records, including documentation supporting project expenditures, in accordance with the sponsors’ requirements. Since its implementation in 2007 these records are stored electronically via document imaging system.

2100 – Sponsored Projects

Research Services

Last Reviewed June 2023

2133 – Advances of Cash from External Sponsors

Some federal agencies and some non-federal sponsors provide cash in advance of the work to be performed under a sponsored project. This policy establishes the appropriate accounting treatment of these cash advances.

2100 – Sponsored Projects

Research Services

Last Reviewed June 2023

2134 – Expense Approval and Documentation Requirement

To provide an understanding of required documentation indicating approval for expenses charged to sponsored projects

2100 – Sponsored Projects

Research Services

Last Reviewed June 2023

2135 – Monitoring Subrecipients Not Subject to OMB Uniform Guidance

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)

2100 – Sponsored Projects

Research Services

Last Reviewed June 2023

2136 – Principal Investigator Eligibility

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

2100 – Sponsored Projects

Research Services

Last Reviewed June 2023

2137 – Revised Final Financial Reports

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.

2100 – Sponsored Projects

Research Services

Last Reviewed June 2023

2138 – Direct Cost Expenditures for Non-Federal Organizations

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.

2100 – Sponsored Projects

Research Services

Last Reviewed June 2023

2139 – Faculty Summer Effort & Salary

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.

2100 – Sponsored Projects

Research Services

Last Reviewed June 2023

2140 – Sponsored Projects Compliance Certification Program

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

2100 – Sponsored Projects

Research Services