2140 - Sponsored Projects Compliance Certification Program

Document purpose

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

effective

October 2005

revised

May 2020

Reviewed

May 2020

Responsible Office

Research Services

Approval

Research Services

The Policy

Individuals who have any of the following administrative responsibilities related to sponsored projects either at the department, school, or central level are required to complete Sponsored Programs at Penn (SP@P) Training:

  • assist faculty with the preparation of proposals requiring the individual to make determinations of allowability, allocability, and reasonableness in accordance with sponsor guidelines, federal regulations, and University and School/Center policies/procedures and regulatory requirements;
  • review and approve expenditures at the central level;
  • provide counsel and advice to faculty regarding proposal preparation, budget preparation; •provide counsel and advice to department/school regarding proposal preparation, budget preparation;
  • review and approve proposals at the central level;
  • provide counsel and advice to faculty regarding cost transfers, effort reporting or overall award management;
  • provide counsel and advice to department/school personnel regarding cost transfers, effort reporting or overall award management;
  • have financial audit responsibility;
  • are responsible for the monitoring of awards, reviewing financial reports for accuracy and compliance and assuring that charges are allowable, properly allocated and reasonable;
  • are responsible for the submission of financial reports/invoices to sponsor; and
  • assist and/or participate in the monitoring of sponsor requirements regarding the timely submission of required non-financial reports.

The senior business officer (or his/her designee) of each school or the divisional Vice President (or his/her designee) is responsible for:

  • identifying those individuals in their operations who fulfill any of the above roles and/or functions;
  • ensuring that the identified individuals successfully complete the SP@P training; and
  • ensuring that all new hires (including internal transfers) to a department fulfilling the above roles and/or functions complete the SP@P training.