Monthly Review and Quarterly PI Review and Certification Process
Following is an overview of monthly review and quarterly certification policy requirements and procedures.
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Monthly Expenditures in the eCertification System
Project expenditures displayed in the eCertification system are the basis for cost reimbursements to Stanford. Sponsored project and cost sharing accounts must be reviewed by the Research Administrator and the review recorded/verified quarterly in the eCertification system Review is expected to be completed before the quarterly certification by the PI.
Any questionable charges must be brought promptly to the PI's attention, and, if needed, corrected by an appropriate transfer. Transfers should be initiated as soon as possible after a need has been identified. Procedures governing transfers of expense are defined in RPH, 15.8 Cost Transfer Policy for Sponsored Projects.
The Research Administrator will acknowledge the following attestation in the eCertification system.
I have reviewed the three months of expenditures for this quarter. To the best of my knowledge, all expenditures are appropriate. Where required, corrections have been or will be made through the accounting system. I understand that to be considered timely all corrections must be made in accordance with RPH 15.8, Cost Transfers for Sponsored Projects.
What is Reconciliation?
Reconciliation is the process of comparing the entries in the eCertification System to supporting documentation and resolving any discrepancies. Most supporting documentation can be found by drilling down on specific expenditure in the system. Reconciling accounts on a regular basis, after month-end close, will help you to manage your sponsored funds to ensure that expenditures and revenues are within appropriate limits and guidelines. Reconciliation is an internal mechanism that ensures that:
- entries and balances are accurate and valid
- records are accurately recorded
- unauthorized changes/charges did not occur
- discrepancies are resolved in a timely fashion
How Do I Reconcile?
- Review expenditures that you don't recognize or appear unusual.
- Compare transactions to source documents as needed.
- Review infrequent transactions.
- Investigate and resolve differences.
Key Components of Reconciliation
Below is a summary of key components of reconciliation. Your reconciliation process may be more or less detailed than the process listed below depending on many factors, such as upfront controls, experience, knowledge, the type of transaction, and the associated risk. Confirm for all expenditures that:
- the expenditures belong on the PTA
- the amount charged is accurate
- the correct Expenditure Type was used
Salary
You must confirm:
- that the amount charged is the same as the percentage incurred
- for hourly employee, hours are correct if amounts charged appear unusual
- the correct expenditure type was used (based on JCC codes)
- the earning codes (for reconciliation)
Benefits
Ensure proper documentation of all vacation/sick leave taken by use of the AXESS time keeping system.
Equipment
Verify the expenditures on statement are what you expected.
Ensure that:
- the amount charged is consistent with order information
- the correct expenditure type was used
- those with multiple allocations are correctly allocated and the rationale for allocation is documented
- equipment is received in period by reviewing the packing slip-if the purchase is near the start or end date of an award
- equipment is properly recorded in Sunflower within 30 days of receipt
Supplies
Verify the amounts charged are what you expected, and review source documents as needed to investigate unexpected amounts.
Confirm that:
- the expenditures belong on the PTA
- the amount charged is accurate
- the correct expenditure type was used
Travel
Verify the amounts charged are what you expected. Verify the travel is allowable on the project. Reconcile expenditures to the source documents as needed. Confirm the correct expenditure type was used, considering unallowable codes as needed.
Other Expenses
Verify the amounts charged are what you expected, and review source documents as needed to investigate unexpected amounts.
Consultant/Subawards
Verify the amounts charged are what you expected and reconcile expenditures to the invoice submitted. Confirm that:
- the invoice amount is within budget
- the correct expenditure type was charged (especially after the first $25,000 of a subaward)
- the subrecipient has complied with award terms
Fringe/Indirect Cost/Infrastructure Rates
Ensure the correct rate is being applied. Do not calculate the rates only verify the correct rate is being used.
Review in the eCertification System
In addition to monthly reconciliation, expenditures must be reviewed by the research administrator (Task Manager) and reviewed and certified by the Principal Investigator each quarter. The reviewer must certify their review quarterly via the eCertification System. The PI can begin to review and certify as soon as the Research Administrator has completed and documented their review of quarterly expenditures in the eCertification System.
Review by the research administrator should include compliance areas such as those covered in the detailed steps below.
Steps in Monthly Review
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Process
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Current Guidance |
Tools & Reports to Assist this Process
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Does the budget match the award, or other budget information? |
Verify the expenditure report matches the sponsor & Stanford's Notice of Award Open tasks opened if cost sharing is required |
Sponsored: To verify budget accuracy, use the sponsor's Notice of Award. Capital Projects: Contact Capital Accounting if you have questions about the budgets. Review Cardinal Curriculum Managing Sponsored Projects
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If the PI wants to rebudget- is it allowed by the sponsor? |
A change in scope always requires approval |
Refer to Sponsor Notice of Award terms and conditions. In the eCertification System this can be found on the Account Detail page by click on the "i" icon. Resource: Award Terms and Conditions |
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Are there any unusually large or small expenditures in relation to the budget, prior months' trends, or other expectations?
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If so, correct “genuine ”errors, such as:
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Review the Commitment Management System (CMS). The following policies, reports, and job aids are available for your reference and use: Administrative Guide Memo 3.1.3 “Activity/Accounts”Overview of iJournal Module of Oracle Financials Cost Transfer Policy for Sponsored Projects Overview: About the Labor Distribution Module of Oracle Financials Reports available in OBI: FIN_EXP_150_Spo_Funded_Amt_Vs_Act_OD (realtime) Reports Available re: Suspense Account in OBI: Finance-Payroll & Labor Management Dashboard |
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Are all expenses:
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Review for compliance with policies. |
Allocability Discussion List of Unallowable Expenditure Types Reports available in OBI:
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Are salaries appropriate and charged to the appropriate PTA and Expenditure Type, or if not, have corrections been initiated? |
Salaries may be held in an Org suspense account and must be cleared. If you have questions about whether or not you have salaries in a suspense account, contact your department administrator. Corrections to salary errors are done with a LD Adjustment; expenditure type corrections must be processed through the Payroll Department. If a wrong PTA was used, correct through an iJournal. To ensure these errors don’t repeat, make the change in the Labor Distribution schedule. |
Check the "Quick Steps: Calculate Vacation Accrual" Reports available in OBI: Finance & Labor Management Dashboard re: labor distribution and earnings by PTA View 100% Salary Distribution in the eCertification System. |
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Does effort for "Key Personnel" appear to match the award, or if not, are sponsor notifications required? |
Note: A change in scope or a reduction in PI effort of 25% or more requires sponsor approval. Propose salary as anticipated by the project scope. |
Review the effort committed in the awarded budget & Sponsor's Notice of Awards. In the eCertification System this can be found on the Account Detail page by click on the "i" icon. |
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Does the NIH salary cap apply to any of these charges, and if so, was it properly treated? |
The difference must be identified on the PeopleSoft Job Earnings Distribution Panels using the special Expenditure Type, “RBE UNALW SLRY OVER CAP 51190" (RBE =Regular Benefits Eligible) Adjustments can be made via labor distribution. |
See DoResearch Topic Salary Caps |
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If vacation or disability sick leave has been taken, has it been properly accounted? |
Time-keeping at Stanford is maintained in Axess Time and Leave. For proper accrual and credit of vacation and sick leave, it is essential all employees input all leave into this system. Verify leave by reviewing your Expenditure Detail Report. |
Run a Leave Accrual Detail report (PS_TL006) in PeopleSoft. Commitment Management System |
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Have the correct fringe benefit rates been applied? |
Don’t calculate the rate; just verify the correct rate was used (e.g.: faculty salary, student, etc.). |
Commitment Management System (CMS) |
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Has equipment been pre-approved (if necessary) and recorded in Sunflower? |
Check your agreement to ensure the equipment is pre-approved (if not, contact the sponsor through OSR/ERA/RMG to obtain approval). Ensure your Department Property Administrator (DPA) has tagged and entered the property into Sunflower. |
Refer to Sponsor notice of award documents. In the eCertification System this can be found on the Account Detail page by click on the "i" icon. |
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Has title been reflected with the proper Expenditure Type and if sales tax is applicable, is it properly charged? |
Generally, sales tax must be applied to purchases with title vested to Stanford, but is not applied to purchases where title of equipment or material vests in the federal sponsors. Review transactions to verify sales tax has been applied correctly. |
Expenditure Type Table for Property and Equipment |
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Are you fabricating equipment? Have fabrication projects been coordinated through the Property Management Office (PMO) and properly documented? |
Verify all fabrications have either been created or converted with the appropriate PTA (and that the task is noted “fabrication”). Ensure a fabrication request form is on file. |
View the Fabrication Procedures - outlined in the Property Manual |
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Are travel expenses allowable, allocable, reasonable and consistent? |
Review these expenditures for reasonableness, appropriateness and compliance with policy (e.g. pre-approved where necessary, lowest available fares, correct per diems or receipts for reasonable and actual expenses).
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Fingate Travel Page Expense Guidance For Business Meals Administrative Guide Memo 36.7 “Travel”
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Does the project have a subaward? If so, has the PI reviewed the Subaward’s invoices? |
Ensure expenditure types are correct as this affects the IDC calculation (remember, indirect costs are only charged to the first $25,000 of a subaward). Are all expenses:
Has the PI reviewed and certified approval of the invoice? Subaward invoices require the following statement to accompany the PI’s signature: “In signing below I approve payment of this invoice and attest that the charges appear reasonable, and progress to date on this project is satisfactory and in keeping with the statement of work.” |
DoResearch Topic Subawards
Expenditure Details Data Download The Cardinal Curriculum - Subawards If you manage a subaward you must take DOR-1122, Subawards: Recognizing, Processing, Managing. |
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Are tuition charges made to the correct PTA and Expenditure Type? |
During the first months of the quarter tuition appears as 51960 "Beginning Term Tuition Allowance Prepaid". At the end of the term they are transferred centrally to 51975 "Tuition Allowance." |
Administrative Guide Memo 24.2 “Graduate Student Assistantships” Salary and Tuition Allowance Tables
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Are the F&A rates or the Infrastructure Charge rates correct, and have they been applied to the correct base? |
Don’t calculate the rate; just verify the correct rate was used (e.g.: infrastructure, or for sponsored if the work is being performed off campus, was the off campus rate used, etc.) |
Administrative Guide Memo 37.3 “Infrastructure”
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Have appropriate credits posted, e.g., prior transfers, sales of surplus property, program income? |
Review for reasonableness and appropriateness. |
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Have the correct PTAs and Expenditure Types been used, or if not, have corrections been initiated? |
If expenses are charged to an incorrect PTA or the wrong Expenditure Type was used, correct them via iJournals. For salary corrections, refer to the "Salary Step". |
DoResearch - Cost Transfers Create Salary Distribution Adjustment in LD
labor adjustment detail in OBI: Finance-Labor and Payroll Management Dashboard labor adjustment detail in OBI: Finance-Labor and Payroll Management Dashboard |
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If cost sharing was committed on a sponsored project, has cost sharing been incurred and charged to the appropriate cost sharing PTA? |
Cost sharing requires a new task and award. Contact OSR for a cost sharing task if you don’t see one on your report. |
DoResearch- Cost Sharing Reports available in OBI: Award Configuration Report (Real-time) |
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If charges on this PTA have been allocated, is the allocation basis documented? If costs are charged via allocation journal, has proper authorization been obtained? |
Regardless of funding source all expenses must be allocated based on a reasonable allocation method. Sponsored Projects must clearly document allocability. |
Cardinal Curriculum: Allocability Discussion Commitment Management System |
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If this award is nearing the “end date”, review:
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Financial closeout should be completed if possible. Remember – even if we can’t perform a financial closeout on a project, we can still submit technical and patent information to the sponsor. |
Commitment Management System
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Do you expect this PTA will go into overdraft, and if so, are there actions to take? |
1. Take care to note if PTA appears to be heading for overdraft – especially if there are missing items and there is little or no funding left. 2. If you know the PTA is in overdraft before the end date, transfer charges as appropriate to a benefiting PTA. 3. After the end date an overdraft must be transferred to a “cost sharing task”. 4. If total overdraft is less than $500, transfer lump sum (net of indirect costs) Expenditure type 56135 to an appropriate unrestricted PTA. |
Administrative Guide Memo 34.1 “Activity/Accounts”RPH 3.2 Fiscal Responsibilities of the PI - Overdraft's section Commitment Management System Reports available in OBI: 150 - SPO Funded Amount and OD |
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Has appropriate documentation been retained (on-line and centrally-filed, or in department files and does it match to the charges? |
Confirm that documentation exists and supports charges on expenditure report (including receipts for Purchasing cards.) |
The eCertification system contain much of the supporting documentation. You can also upload supporting documentation in the Comments and History tab on the Account Detail Page. Reports available in OBI: Expenditure Details Data Download |
Quarterly PI Review and Certification
The PI has overall responsibility for the technical and fiscal management of a sponsored project. This includes the management of the project within funding limitations, adherence to reporting requirements and assurance that the sponsor will be notified when significant conditions related to project status change. While responsibility for the day-to-day management of project finances may be delegated to administrative or other staff, accountability for compliance with Stanford policy and sponsor requirements ultimately rests with the PI.
The eCertification System is the official record of project expenses and the basis for cost reimbursements to Stanford. This system is where the PI will review and certify project expenditures.
Sponsored project and cost sharing accounts must be reviewed and certified by the PI quarterly in the eCertification system for every sponsored project and cost sharing account.
The purpose of the review and certification is to confirm that all expenses charged to the account are allowable, allocable to the project, and reasonable. The certification of salary expenditures confirms that salaries charged to the account are supported by a corresponding expenditure of effort during the time period being certified. The certification also assures that other expenditures are for items or services purchased and used during the project period as specified by the award.
Faculty who are not Principal Investigators and whose salary is charged to sponsored projects must review and certify their payroll distribution.
The following certification statement appears in the eCertification System.
As the principal investigator I confirm that to the best of my knowledge, salary and wages charged to this project are appropriate in relation to work performed on this project. All other costs charged to this project are, to the best of my knowledge, appropriate. Where required, corrections have been or will be made through the accounting system.
Expenditures must be reviewed and certified by the certification due date, which is approximately 75 days after the end of the academic quarter being certified.
Adequate explanation and documentation for all project charges expenditures must be maintained for four years after the Stanford sponsor closes out the award. Where documentation cannot be provided as to the allowability, allocability and reasonableness of any project expenses, including but not limited to expenses incurred late in the project period, the sponsor may deny them. In this case, the PI, department or school will be expected to cover the expense from unrestricted appropriate sources. All data in the eCertification System will be retained by ORA in accordance with University record retention requirements for sponsored projects (see Guide Memo 3.1.5: Retention of Financial Records).
Any departure from the policy or procedures regarding summarization of Quarterly PI Review and Certification must be approved in advance by the Office of the Vice Provost and Dean of Research (DoR) and Research Financial Reporting (RFR) within ORA.
