Compliance
When the university accepts a federal award or sub award, we agree to comply with all applicable federal requirements. This includes:
- prudent management of funds and actions affecting the award
- ensuring that all expenditures are allowable, allocable, reasonable, and necessary to the project
- timely submission of reports and invoices
- meeting cost share obligations
- monitoring sub awards
- complying with established procurement standards
Compliance Order of Precedent
There are many regulations that govern the compliance requirements of a sponsored project. The new Uniform Guidance issued by the Federal Office of Management and Budget went into effect December 26, 2014. This is the overarching compliance regulation for all federal awards issued after December 26, 2014.
When regulations differ, the most restrictive option applies. Otherwise we adhere to the following order of precedent:
- OMB Uniform Guidance (or A-21 as grandfathered)
- Agency Policy Manuals
- Terms and Conditions of the Award Notice
- Institutional Policies and Procedures
Consequence of Noncompliance
The consequence of not complying with federal mandates can be severe not only for the university but also for the individuals responsible for project management. Possible repercussions includes:
- more stringent oversight and review status from the granting agency
- award reduction or termination of project
- increase audits and reviews from other federal agencies
- suspension or debarment
- criminal and civil penalties