2019 SACSCOC Reaffirmation

Compliance Narratives


13.5 - Control of Sponsored Research/External Funds


The institution maintains financial control over externally funded or sponsored research and programs. (Control of sponsored research/external funds)

Judgment of Compliance

Compliant

Narrative


Sam Houston State University (SHSU) maintains financial control over externally funded and sponsored research through the Office of Research and Sponsored Programs (ORSP), the Office of Finance and Operations, and the Office of Research Administration. The Office of Research and Sponsored Programs oversees the pre-award and contracting processes, while the post-award process is managed through the Office of the Associate Vice President for Finance and Operations in conjunction with the Office of Research Administration. Each of these offices develops annual assessment plans with goals and assessment measures to monitor success at achieving those goals.

The SHSU policies that govern research administration are as follows:

  • Finance & Operations Policy FO-ORA-08, Budget and Expenditure Monitoring [1]
  • Finance & Operations Policy FO-ORA-4, Budgeting & Revisions [2]
  • Finance & Operations Policy FO-ORA-06, Cost Share [3]
  • Finance & Operations Policy FO-ORA-02, Cost Transfer [4]
  • Finance & Operations Policy FO-ORA-03, Effort Certification [5]
  • Finance & Operations Policy FO-ORA-10, No Cost Extension [6]
  • Finance & Operations Policy FO-ORA-09, Project Close-Out [7]
  • Finance & Operations Policy FO-ORA-05, Records Retention [8]
  • Finance & Operations Policy FO-ORA-01, SHSU Fixed Price Agreements [9]

Pre-Award

ORSP, under the direction of the Associate Vice President for Research, is responsible for the operations of pre-award administration. As the primary office responsible for ensuring compliance with proposal policies, ORSP directs the pre-award administration. During the proposal development stage, ORSP is charged with ensuring compliance with the Texas State University System’s (TSUS) Rules and Regulations [10] and the sponsoring agencies’ guidelines (e.g., the National Science Foundation [NSF] and the Office of Justice Programs) [11] [12]. This responsibility includes preparing budgets, as well as approving and submitting proposals. ORSP is also responsible for post-award non-financial administration, such as Institutional Review Board and Institutional Animal Care and Use Committee protocols.

Post-Award

The Associate Vice President for Finance and Operations and the Office of Research Administration are responsible for the operations of post-award administration. Post-award financial administration is handled through the Office of Research Administration. Through a combination of tasks performed by the Office of Research Administration and by the college and department administrative offices, expenditure transactions are reviewed for compliance with applicable laws, regulations, University policies, and specific award conditions. The following is a list of activities and compliance-related programs implemented and administered by the Office of Research Administration:

  • Quarterly distribution of effort certifications
  • Periodic review of deficit accounts
  • Verification of billing and reporting instructions in accordance with contract information
  • Review of cost transfers and purchase requisitions for allowability
  • Review of expenditure documents to ensure allowability and correct coding
  • Review of contract and grant awards for legal sufficiency

In addition to the processes performed by the Office of Research Administration staff, the department is responsible for working with other administrative offices in developing efficient and effective internal controls for sponsored projects. The Office of Research Administration provides required financial information needed during federal and other financial audits of sponsored projects. All sponsored program principal investigators have primary responsibility for being compliant with University fiscal procedures. With the assistance of the Office of Research Administration and ORSP, principal investigators maintain primary responsibility for financial control over their sponsored projects. The Office of Research Administration continually provides training to new principal investigators so that they understand the importance of their role in the SHSU grant process [13].

Facilities and Administrative Costs (F&A)

SHSU is operating under a provisional rate agreement of 35.5% of modified total direct costs (MTDC) with the Department of Health and Human Services [14]. The on-campus rate is 35.5% MTDC and the off-campus rate is 10.33% MTDC.

Training Programs

The Office of Research Administration conducts one-on-one individualized training programs for principal investigators and staff through new principal investigator kick-off meetings when new awards are issued. Principal investigators are provided with information regarding the overall grant process and the adherence to applicable federal and state law and university policies. Investigators are informed of the consequences that may result from noncompliance. The Office of Research Administration also provides access to electronic project statements to assist principal investigators in reviewing their award expenditures for accuracy and completeness. Each principal investigator can review these on demand both at the summary and detail levels by category [15] [16].

Audits

The State of Texas contracted independent external certified public accountants (CPA) to conduct the federal portion of the 2017 statewide single audit. The federal portion includes a review of compliance and controls over the State’s federal awards as required by Uniform Guidance. In addition, they conducted an audit of the schedule of expenditures of federal awards [17]. The report, along with the financial portion of the statewide single audit performed by the State Auditor’s Office, was submitted to the federal government to fulfill Single Audit reporting requirements. There were no findings relating to SHSU in the external CPA review of federal funds or in the State Auditor’s financial audit.


Supporting Documentation

Documentation Reference Document Title
[1] Finance & Operations Policy FO-ORA-08, Budget and Expenditure Monitoring
[2] Finance & Operations Policy FO-ORA-4, Budgeting & Revisions
[3] Finance & Operations Policy FO-ORA-06, Cost Share
[4] Finance & Operations Policy FO-ORA-02, Cost Transfer
[5] Finance & Operations Policy FO-ORA-03, Effort Certification
[6] Finance & Operations Policy FO-ORA-10, No Cost Extension
[7] Finance & Operations Policy FO-ORA-09, Project Close-Out
[8] Finance & Operations Policy FO-ORA-05, Records Retention
[9] Finance & Operations Policy FO-ORA-01, SHSU Fixed Price Agreements
[10] The Texas State University System, Rules and Regulations, Chapter III, Section 10
[11] National Science Foundation Proposal and Award Policies and Procedures Guide
[12] Office of Justice Programs Guidelines
[13] PI Training Opportunities
[14] Provisional F&A Rate Agreement from the Department of Health and Human Services
[15] General Accounting Report (GAR) – Example (Summary) – Redacted
[16] General Accounting Report (GAR) – Example (Detail) – Redacted
[17] State of Texas Federal Portion of the Statewide Single Audit Report for the Year Ended August 31, 2017