US Federal Award Requirements
US federally funded awards include those received from US government agencies (NIH, NSF, NASA, Department of Defense, etc.) as well as all funding from US government agencies that is passed through from prime or lead institutions.
For NIH policies that outline eligibility of expenditures, audit requirements and administrative requirements please review the NIH Grants Policy Statement (GPS).
Because Western spends in excess of $750,000 US in US government funds our awards are subject to an annual Single Audit. These audit requirements are different and more stringent from Canadian audits. They are coordinated by the Research Finance office and conducted by our corporate external auditors, KPMG.
- Equipment purchases exceeding the micro-purchase threshold of $10,000 US require multiple quotes prior to requisition approval. This threshold aligns with Western’s procurement policy (CDN$).
- An inventory of assets with a purchase price greater than $5,000 US will be taken at least once every 2 years and compared with the US asset inventory list as per requirement 2 CFR 200.313(d)(2). A representative from Procurement Services will contact grant recipients to confirm location and condition of the assets.
- Assets may not be disposed of, resold or given away without appropriate approvals and completion of an asset disposal form. Contact Procurement Services for assistance.
- Purchase of assets greater than $25,000 that were not a component of the original scope of work and the approved budget require pre-approval. (NIH Grants Policy Statement – 7.9.1 exhibit 5)
The grant recipient is expected to attest (sign off) on all financial reports, confirming that the reported expenditures relate directly to project activities and conform to the terms and conditions of the award.
Agency guidelines require adequate time and effort reporting, which validates that salaries charged to research projects match the effort expended on the award. A regular review of salary expenses should be conducted by the grant recipient. Key personnel contributing to the research activities and outcomes of the project, but not being compensated from project funds should also track their effort. Research Finance will request signed confirmation of employee effort at least once annually. This may also be reviewed during the annual audit.
Information regarding eligible costs for NIH grants can be found in Section 7 of the NIH Grants Policy Statement. A chart showing a select list of expense examples is included. Other US Federal agencies also have their own guidelines regarding expense eligibility. Additional cost considerations can be found in the US government's "Uniform Guidance" – Subpart E of both 2 CFR 200 and 45 CFR 75. In addition, individual award agreements may also define specific areas of ineligible expenditures. It is the grant recipient’s responsibility to ensure that all expenses charged to the project account are eligible according to the funding agency's policies.
Fly America Act stipulates that when traveling on US government funds travelers must use a federally approved carrier when entering and leaving the US.
Journal entries transferring charges to US federally funded grants must be directly related to the funded research and must identify the original invoice or expense source. Entries to simply expend unspent funds are not permitted.
Changes to the scope of work as defined in the application and/or the award notice must be approved by the funding agency.
As a foreign institution Western’s overhead rate on NIH awards is 8%. This is always applicable even when Western is not the lead institution. For other agencies Western’s negotiated F&A rate is used or a rate as specified in the program literature.
Unspent US federal funds must be returned to the agency at the end date of an award. Research Finance monitors this and contacts grant recipients as end dates approach, but grant recipients remain responsible for monitoring the balances in their projects. NIH offers extensions up to one year after the end date provided the extension is requested prior to the end date of the award. Please contact Research Development & Services for assistance. The grant recipient and their department bear the responsibility for any ineligible costs or over expenditures arising when an extension is not applied for or approved.
Closeout of an NIH award confirms that all applicable administrative actions and all required work of an award have been completed by the grant recipient and NIH. Closeout requirements can be found in the GPS Section 8.6. Failure to submit timely and accurate final reports may affect future funding to Western. The grant recipient must ensure all applicable close out reports are submitted not later than 120 days after the project end date.
- Final Federal Financial Report – prepared and submitted by Research Finance
- Final Progress Report – prepared and submitted by the grant recipient
- Final Invention Statement and Certification – prepared by grant recipient, approved and submitted by Research Development & Services