Reporting/Invoicing

Federal funds must be expended consistent with:

  • The purpose for which the award is made
  • The terms of the approved budget by the sponsor
  • All applicable Federal OMB circulars (A-21, A-110, A-133)
    • OMB circular A-110 prescribes Federal Agency requirements for the administration of Grants and Cooperative agreements.
    • OMB circular A-21 prescribes Cost principles for Educational institutions.
    • OMB circular A-133 prescribes Audit requirements for financial management systems and internal procedures, as well as compliance with terms and conditions of the federally sponsored award.

Although most Federal awards will fall under general agency guidelines, any award could have specific restrictions or reporting requirements that should be addressed.

As some sponsors will have different requirements, the following is provided as general guidance on how to review accounts and complete documentation for an FSR/Invoicing. The specific sponsor terms and conditions must be reviewed for particular items such as rebudgeting authorities, prior approvals, request for extensions, report filing dates for financial reports and monthly/quarterly invoicing.

A monthly review of the award should be undertaken to ensure that each account is reviewed for compliance issues, cost-share, allowable costs, outstanding payments, etc. The purpose of the review is to identify and correct problems on a timely basis and to ensure that there will be few problems when completing the final FSR/Invoice or closing out an award. The monthly FSR/ invoicing review process is also used to assess the general health of the account and the Compass database and to identify issues, which may need attention, by OGCA, the Principal Investigator or the Departmental Administrator.

The use of a checklist is strongly encouraged. The purpose of the checklist is to provide an easy monitoring mechanism to ensure that all aspects of an award's status have been reviewed. ARRT (Award Reconciliation and Review Tool) has been developed to assist with managing awards ongoing.

Most of Emory's Federal Awards are LOC Type (Letter of Credit) and should be reviewed monthly for proper and allowable costs as prescribed by the OMB circular A-21 and Emory's policies and procedures.

State and Local Governments

Billing/Invoicing awards do not normally require a financial report. Most State and County awards require monthly invoicing and a few will have a quarterly invoice. Occasionally, a sponsor may require an FSR, in addition to the final invoice. The FSR and the final invoice must reconcile. Deadlines for billing accounts tend to be shorter than FSR awards. Most State and County awards have a 15 to 45-day report cycle. Billing /invoicing deadlines must be met as a late receipt could result in non-payment.

Fixed fee awards (mostly non-federal Clinical Trials) do not normally require financial reporting and are invoiced monthly or quarterly, if specified in the agreement. Therefore the review process is normally limited to F&A cost calculations, revenue collections, budget redistributions, extensions and residual funds transfers.

The Emory award number and the sponsor's award number (if any) should be included on every financial report/invoice, even if not required on the sponsor form. This will facilitate payment posting and reduce incorrect posting.

The majority of State awards terminate as of June 30th, which is also the end of the State fiscal year. The State is very strict about the timing of final June invoices and no-cost-extension requests or rebudgeting requests. They will not pay invoices if they are not received by their deadline, in most cases within 30 days of the award end date.

Be aware that some state/county programs require even shorter reporting periods- 10-15 day finals.

It is highly recommend that a careful review be completed one month earlier to make sure all necessary charges and/or corrections are on the State/County award no later than the 30 days prior to the end date of the award. The final month ledgers should be as correct as possible. There should not be a lot of additional charges or cost transfers. Please note: In most cases, the State is receiving copies of the of the SPP2242 report with labor details as part of the invoicing process. They are very aware of cost transfers and will be sensitive to late charges and corrections.

NON-GOVERNMENT FINANCIAL STATUS REPORTING/INVOICING

The important thing to remember for foundations, Industry and other non-profit organizations, is to review the sponsor terms and conditions thoroughly. Most foundations and other non-profit organizations have a 30-60-day final financial reporting cycle, though many have quarterly or semi-annual financial reporting requirements.

Some foundations require monthly detailed invoicing in addition to final financial reports and have strict rebudgeting guidelines, restrict carryover funds and require that unexpended balances be returned.

Meeting FSR/ Invoicing deadlines is important for future funding and on-going sponsor relationships.

The important thing to remember for foundations, Industry and other non-profit organizations, is to review the sponsor terms and conditions thoroughly. Most foundations and other non-profit organizations have a 30-60-day final financial reporting cycle, though many have quarterly or semi-annual financial reporting requirements.

Some foundations require monthly detailed invoicing in addition to final financial reports and have strict rebudgeting guidelines, restrict carryover funds and require that unexpended balances be returned.

Meeting FSR/ Invoicing deadlines is important for future funding and on-going sponsor relationships.

Some sponsors require Final Inventory Listing of Emory-owned equipment acquired with sponsor funds. Please be aware that even though not normally exercised, some Sponsors retain the right to transfer title of the equipment to other sponsor funded projects, possibly at other institutions. Generally, this right must be exercised by the sponsor within a specified period of time, usually 120 days from the termination date of the project. All sponsors require Final Property Reports of Sponsor-owned equipment. It is OGCA's responsibility, in conjunction with the departmental administrator and the principal investigator to submit these reports to the Sponsor.

All patent reports that indicate a disclosure and/or invention are coordinated with the Office of Sponsored Programs and the Office of Technology Transfer. The final patent reports for grants awards are processed and submitted by OSP.

OGCA does not monitor, maintain, or require that copies of Final Technical Reports be submitted to OGCA. However, timely submission of the Final Technical Report is of great importance since Sponsors may hold final payment until the Final Technical Report has been received and accepted. When this is the case, OGCA will contact the Departmental Administrator and Principal Investigator to inform them of their responsibility to ensure that the delinquent report is submitted. The Departmental Administrator is asked to provide OGCA with a copy of the cover letter transmitting the Final Technical Report. OGCA can then contact the Sponsor and inquire regarding the status of the held final payment.

Federal agencies require financial reporting for Program Income. Program Income is income earned by a grant recipient from activities which are supported by the direct costs of an award. It includes, but is not limited to:

  • Fees earned for services performed under the grant, such as those resulting from laboratory drug testing
  • Rental or usage fees, such as those earned from fees charged for the use of computer equipment purchased with grant funds
  • Funds generated by the sale of commodities, such as tissue cultures, cell lines, or research animals
  • Fees received to attend conference or workshop funded by a sponsored project

Unless otherwise specified in the awarding agency regulations or the terms of the award, program income does not include:

  • The receipt of principal on loans, rebates, credits, discounts, or their subsequent interest
  • Interest earned on advances of federal funds
  • Income earned from license fees and royalties for copyrighted material, patents, patent applications, trademarks and inventions produced under an award
  • Income earned after the end of the project period

Per OMB Circular A-110 (Section .24, Program Income) [PDF], program income is retained by the award recipient and used in one of the following ways:

  • Option 1: Added to funds committed to the project by the awarding agency and used to further project directives.

  • Option 2: Used to finance the non-federal share of the project or program.

  • Option 3: Deducted from the total project allowable cost in determining the net allowable costs on which the federal
    share of costs is based.

Agency regulations or the terms of the award normally specify the option to be used.