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Transaction Controls and Notice of Award Distribution

Procedure: 8-15

Effective: August 1, 2004

Owner: Assistant Vice President for Research Administration in the Office of Sponsored Programs

Latest Revision: May 7, 2010

Procedure Steps | Scope | Policy | Responsibility | Distribution | Ownership

Scope

This procedure covers the application of expenditure controls to sponsored program awards and projects, and the distribution of transaction control information to departments. It is also important to note that these transactions controls are an aid to insuring expenditure compliance. The ultimate compliance responsibility however, still lives with those who are processing the charges. Transaction controls are not all inclusive or exclusive.

System References

  • Proposal Approval Sheet
  • Sponsored Program Notice of Award
  • Transaction Control Template – Federal Awards
  • Transaction Control Template – Subcontracts
  • Transaction Control Template – Fellowships and Training Grants
  • CAS Exceptions Supplemental Form

Policy

Responsibility

The Director of Accounting and Award Management in the Office of Sponsored Programs is responsible for ensuring the application of transaction controls to sponsored research awards according to this procedure and to the relevant and applicable regulations governing the charging of direct costs to such awards.

Distribution

  • Office of Sponsored Programs Administrators
  • Associate Deans
  • Fiscal Contacts
  • Research Administrators

Ownership

The Assistant Vice President for Research Administration in the Office of Sponsored Programs is responsible for ensuring that this procedure is necessary, reflects actual practice, and supports University policy.

Procedure Steps

These procedures apply to all grant and contract projects.

Transaction controls prevent the charging of certain expenditure types to a grant or contract.

Transaction controls are used as a way of improving University compliance with sponsor and federal requirements.

NOTE: Transaction control information is only distributed with the Notice of Award if a change has been made to the standard list of allowable expenditure types. This change is usually effected by means of the CAS exception request. ransaction control templates may also be modified due to changes in sponsor rules, although this is a less common occurrence.

For a listing of the transaction controls on each template please go to the following url: http://www.virginia.edu/sponsoredprograms/TransactionControlsHome.htm

  1. Federal Awards
    All new federal awards except for fellowships or training grants will be assigned on the federal award template.
  2. Subcontracts
    This transaction control template applies to all subcontracts issued to an outside entity. The template restricts direct charges allowed on a subcontract to two types (up to the first $25,000):
    • Contractual Services, Svcs, Subcontracts, OSP No F&A
    • Contractual Services, Svcs, Subcontracts, Spon Pgm
  3. Fellowships and Training Grants
    This transaction control template will be applied to all federal fellowships and training grants.
  4. Non Federal Awards
    This transaction control template will be applied to all non federal grants and updated as necessary to comply with Sponsor guidelines.

OSP will assign transaction control templates to the award types described above at the time an award is made and set up in Oracle. OSP will review the goldenrod proposal approval sheet to determine whether an exceptional circumstance exists for allowing the use of expenditure types, which would otherwise be locked out by the transaction control template for the award.

If, for example, you are submitting a proposal for an award which will include research that involves conducting an extensive survey, you might submit a justification request for the use of postage as an allowable expenditure type, in order that the survey might be mailed out to participants. Postage is generally considered an indirect charge, but in an exceptional circumstance in which there might be a more predominant use of such an expenditure type, an exception may well be granted in order to facilitate research in such a unique circumstance.

PLEASE SEE OSP’s Cost Accounting Standards Guidelines for further details.

SUPPLEMENTAL EXCEPTION REQUESTS

There may be exceptional circumstances that have not been clearly or adequately documented on the goldenrod. Should you need to request the allowability of a particular expenditure type otherwise identified in one of these transaction control templates, a supplemental CAS exception form should be completed and submitted for processing and approval. (The supplemental CAS exceptions form is essentially for use in these “after-the-fact” circumstances.) This document may be submitted electronically or faxed (2-3096) to Sharon Boyd (sgb4n@virginia.edu) in OSP’s Grants and Contracts Office.

NOTE: Transaction controls do not provide the sole means by which costs should be charged to sponsored projects. All costs should be subjected to questions and thoughts of allowability, allocability, reasonableness, necessary and consistency in relation to specific Sponsor, University and Federal guidance.

There is a Discoverer Report that can be run that will identify Transaction Controls by Project.

End of Activity