Sponsored Projects Expenses
Sponsored project funds awarded to and administered by the University are to conform to University policies and guidelines and those of the sponsor. Projects where the University is a subawardee are subject to applicable policies of the sponsor providing the funding, as well as whatever other terms and conditions are specified by the prime awardee.
When the sponsor provides federal funding for the project, either directly or indirectly as pass-through funds, there are specific compliance requirements.
Statutory Requirements are created when laws are enacted, and these requirements take precedent over all other policies and regulations related to sponsored projects.
Office of Management and Budget Circulars for government-wide sponsored project management are as follows:
OMB A-110, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations, applies to grants and cooperative agreements and provides guidance in such areas as property standards, procurement standards, reports and records. (Note that federal contracts are subject to Federal Acquisition Regulations rather than A-110.) Individual agencies implement this Circular in the Code of Federal Relations, which is typically the same as their grant regulation documents. OMB A-133, Audits of States, Local Governments and Non-Profit Organizations, provides uniform requirements for audits of Federal awards. The University is audited annually to ensure compliance with laws and regulations and maintenance of adequate internal controls. Audit reports for recipients subject to Circular A-133 are available at the Federal Audit Clearinghouse.
OMB A-21, Cost Principles for Educational Institutions, applies to grants, contracts, and other agreements with educational institutions and provides principles for determining costs applicable to federal sponsored agreements. (Note that A-21 applies to contracts and to subrecipients performing work under federal awards.)
Federal Demonstration Partnership Terms and Conditions
Bradley University is a member of the Federal Demonstration Partnership (FDP). Therefore, certain research awards from the major federal agencies are subject to FDP General Terms and Conditions and FDP Agency Specific Requirements, rather than the agency grant regulations. Awards received from an FDP agency as a subaward are subject to FDP terms and conditions only if the pass-through entity is an FDP institution. Policy manuals, handbooks, and general grant conditions documents(for grants and cooperative agreements not covered by FDP terms and conditions.) Federal agency grant policy documents apply.
Federal Acquisition Regulations (FAR) are the primary regulations used by federal sponsors to govern contracts for supplies and services, including research services. FAR incorporates OMB Circular A-21 for the purpose of defining allowable costs. FAR is not applied to grants and cooperative agreements that are governed by OMB Circular A-110, agency grant regulations, or FDP terms and conditions. Federal contracts typically incorporate all of the FAR clauses applicable to a given project.
Projects sponsored by State of Illinois and other non-federal sponsors must comply with applicable sponsor policies and the terms of individual sponsored agreements.
Deviations from either University or sponsor policy must be explicitly negotiated and approved by authorized officials of the University and the sponsor.