Financial activity should be monitored on a timely basis to ensure proper posting of expenditures and accurate financial reporting.
The Federal Office of Management & Budget has established OMB Circulars as a government-wide guidance to manage sponsored agreements. The OMB circulars provide uniform standards. As an educational institution, Towson University must comply with the following regulations:
In addition to the federal OMB Circulars, Towson University must comply with sponsor's guidance, policy manual, terms and conditions, and program specific requirements.
Time & Effort Reporting/Release Time
As required by OMB Circular A-21, all Faculty and
Staff working on sponsored agreements are required
to complete a time and effort report. If a time card
is submitted and/or effort is charged directly to
the project, a Time & Effort report is not required.
Time & Effort reports are an after-the-fact confirmation
of actual time dedicated to a project. Total distribution
of effort dedicated to all university activities
should total 100%. One hundred percent effort is
defined as the effort expended to accomplish the
set of activities encompassed by the appointment,
regardless of the actual hours expended on those
activities. Effort should be consistent with the
expectations of the individual's institutional appointment(s)
such as teaching/instruction, research/scholarship,
and administration. Activities such as proposal writing,
consulting and/or other outside professional activities,
leadership in professional societies, activities
associated with appointments at other affiliated
entity should be excluded from institutional workload.
Please refer to the Faculty Handbook Chapter 3, part
III, section XV. http://www.towson.edu/provost/resources/toc.asp
Release time spent on a sponsored project, in-kind
effort (whether mandatory or voluntary committed),
and effort underwritten by the sponsor must be documented.
In-kind committed effort is time a faculty member
has agreed to commit to a sponsored project, but
the cost is not charged directly to the project.
If a faculty member receives release time to work
on a sponsored project and the effort is underwritten
by the sponsor, Academic Affairs will receive a portion
of the amount calculated for release time to cover
the actual cost of hiring a replacement to teach
the course load.
Please refer to the Faculty Handbook Chapter 9,
part II, section VII.
Faculty Time & Effort reports are due
at the end of each semester. Staff Time & Effort reports are due
at the end of each month.
Time & Effort Report form and instructions
can be found here.
Important note: Prior approval
by the sponsor is required if key personnel named
in the award changes or level of effort changes more
than 25% (except where the sponsor's policy is stricter).
Prior approval is also required if the Principal
Investigator will be absent from campus more than
three (3) months.
A subcontract/subaward is an award of financial
assistance to an eligible subrecipient under a grant
or cooperative agreement.
If funds awarded to Towson University are subcontracted
to another institution or organization (subrecipient),
please contact OSPR. OSPR will assist you in establishing
a subcontract agreement with that institution or organization.
Determination of Subrecipient or Professional
Performance is measured against whether the scope
of work is met
Has responsibility for making programmatic decisions
Has responsibility for adherence to applicable
program compliance requirements(e.g. OMB Circulars,
Uses the funds to carry out a project as compared
to providing goods or services for a project
Provides goods or services within normal business
Provides similar goods or services to many different
Operates in a competitive environment
Provides goods or services that are ancillary to
the operation of the research project
Is not subject to program compliance requirements
Federal regulations found in the OMB Circulars A-21,
A-110 and A-133 also flow down to the subrecipient.
The Principal Investigator is responsible for monitoring
the subrecipient's technical and programmatic activities
to ensure project objective(s) are being met and
are in compliance with federal and agency regulations.
The Principal Investigator is also responsible for
approving and signing all invoices submitted by subrecipient.
Subrecipient invoices should include the following:
Towson University's contract number
Current period expenditures
Total expenditures to date
Fiscal agent certification
Post-Award and the Principal
Investigator will review subrecipient's detail transaction
reports and perform random audits of expenditures.
Cost sharing is project costs that are not reimbursed
by the sponsor.
Types of cost sharing:
Mandatory – committed, required
by the sponsor as a condition of the award
Voluntary Committed - not required
by the sponsor, offered by the Principal Investigator
as a demonstration of commitment to the project
Voluntary Uncommitted - not required
by the sponsor and is above the committed and budgeted
cost share, does not need to be tracked or certified
Committed cost share, whether mandatory or voluntary,
is a binding obligation that is auditable and must
be accounted for and documented.
Federal regulations stipulate that:
Federal funds cannot be used to meet cost sharing
Costs used to meet cost sharing obligations cannot
be claimed for other federally funded projects
Costs claimed as cost sharing must be verifiable,
allowable, and reasonable.
Cost sharing methods: In-kind Contributions - existing cost
covered by the University's operating budget (e.g.
effort of faculty that is devoted to project, but not
paid by the sponsor, waived fees, and/or waived F&A). Cash Contributions - new costs requiring
additional funds, which is covered by the department
or with prior approval, Towson University's matching
cost pool. Third party Contributions - external
organization's cash contributions, donations, equipment,
supplies, services, etc.
must document all committed cost sharing. At the
conclusion of the project, the Principal Investigator
must submit a Cost
Share Documentation form to Post-Award Grants
All budget revisions must be reviewed and approved by OSPR
before the budget can be modified.
The budget plan is the financial expression of the
project or program as approved during the award process.
Budget revisions may be necessary if actual needs
of the project change.
Many sponsors allow budget revisions among budget
categories without prior approval (from the sponsoring agency) if the project
scope remains the same and/or the revision does not
exceed a predetermined amount or percentage.
OSPR will work with the sponsoring agency if approval is required.