Judgment of Compliance

Narrative

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

Pre-Award
The Office of Research and Special Programs (ORSP), under the direction of the Associate Vice President for Research, is responsible for the operations of pre-award administration. ORSP, as the primary office responsible for ensuring compliance with proposal policies, directs the pre-award administration. During the proposal development stage, ORSP is charged with ensuring compliance with The Texas State University System’s Rules and Regulations and the sponsoring agencies’ guidelines (e.g., the National Science Foundation (NSF) and the Office of Justice Programs) [1] [2]. This responsibility includes preparing budgets and 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 Contracts and Grants Office are responsible for the operations of post-award administration. Post-award financial administration is handled through the Contracts and Grants Office. Through a combination of tasks performed at Contracts and Grants and at different College 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 Contracts and Grants Office:

• Monthly distribution of effort certifications
• Weekly 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 & grant awards for legal sufficiency

In addition to the processes performed by contracts and grants accounting staff, the department is responsible for working with other administrative offices in developing efficient and effective internal controls for sponsored projects. The Contracts and Grants Accounting Office 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 Offices of Contract and Grants and ORSP, the principal investigator maintains primary responsibility for financial control over their sponsored projects. The President of SHSU made a presentation to each college and sent a memo to each faculty member to explain the importance of principal investigators being up to date on the procedures as well as outlining the services the Office of Contracts and Grants provides to help the institution maintain financial control [3] [4].

Facilities and Administrative Costs (F&A)
SHSU is operating under a provisional rate agreement of 49% Salaries, Wages and Fringes (SWF) with the Department of Health and Human Services [5]. The on-campus rate is 49% SWF and the off-campus rate is 15% SWF. The University’s formal rate agreement has been submitted to the Department of Health and Human Services for final review [5].

Training Programs
The Contracts & Grants Office conducts training programs for principal investigators and staff through a workshop conducted for each of the SHSU Colleges. Principal investigators are provided with information regarding the overall grant process and their adherence to applicable federal and state law, and university policies. Investigators are informed of the consequences that may result from noncompliance. The Contracts and Grants Accounting Office also provides electronic monthly project statements to assist principal investigators review their award expenditures for accuracy and completeness. Each principal investigator receives one report at the summary level by category and one report in detail by category [6] [7].

Audits
The State of Texas contracted KPMG, LLP, certified public accountants, to conduct the federal portion of the 2007 statewide single audit. The federal portion includes a review of compliance and controls over the State’s federal awards and an audit of the schedule of expenditures of federal awards [8] [9]. The report, along with the financial portion of the statewide single audit performed by the State Auditor’s Office [10], was submitted to the federal government to fulfill the OMB A-133 single audit reporting requirements. There were no findings relating to Sam Houston State University in the KPMG review of federal funds or in the State Auditor’s financial audit.

Supporting Documentation