- d
(Approved by authority of the President)
Purpose
This policy ensures compliance with sponsor financial requirements and best practices in fiscal management during the post-award administration of sponsored programs.
This policy:
- Designates the Office of Research and Sponsored Programs Finance with joint responsibility for maintaining University policy on award management through Grants Information Memoranda.
- Establishes responsibilities for providing strong, effective financial management tools for researchers.
- Sets standards for internal controls over the receipt and expenditure of sponsored program funds.
Scope
This policy applies to awards made to the University, including its campuses and medical entities. This policy applies to all University entities unless specifically excluded by the Senior Vice President for Finance, Planning & Budgeting.
This policy does not apply to the Metropolitan Tract or Washington Biomedical Research properties or facilities.
Definitions
Refer to Knowledge Navigator for key terms and definitions.
Awards—An agreement that memorializes the terms and conditions between the University and the sponsor in which the sponsor supports a specific scope of work carried out by the University for organized research, instruction, or other sponsored activity in exchange for something of value, such as data, results, IP rights, or technical reporting.
Grants Information Memoranda (GIM)—UW Research policies, procedures, and guidance for the administration of awards.
Principal Investigator (PI)—The individual(s) with the ultimate authority and responsibility for leading, directing, and reporting on an award intellectually and logistically on behalf of the University.
Subrecipient Monitoring—A University program used to ensure subrecipients are using subawards only for authorized purposes in compliance with federal statutes, regulations, (including 2 CFR 200.332 and GIM 08,) and the terms and conditions of the subaward, and that the subaward performance goals are achieved.
Responsibilities
Principal Investigator
The principal investigator (PI):
- Reviews and certifies costs are appropriately allocated to the award(s);
- Reviews and certifies project staff are qualified and trained appropriately;
- Ensures internal monitoring controls in the fiscal operations of awards;
- Ensures transfers or reclassifications to allowable fund sources occur promptly;
- Ensures funds are spent in accordance with sponsor requirements, University policy, and cost principles;
- Monitors the payment of University generated invoices as well as monitors and approves third party invoice payment, including subrecipient invoices;
- Manages deficits in accordance with APS 38.15.
University Unit (e.g. Campus, School, College, Department)
The PI’s organizational unit:
- Ensures internal monitoring controls are in place to manage the fiscal operations of awards and necessary personnel has access to financial systems for administration and monitoring of award activity.
- Ensures staff responsible for managing departmental resources are qualified and trained appropriately.
- Manages deficits in accordance with APS 38.15.
Office of Research
The Office of Research (OR) is responsible for pre-award sponsored program administration and sponsored program non-fiscal compliance policy, including:
- Setting policy for proposal preparation, review, and submission, including sponsored program proposal budget responsibilities.
- Establishing subrecipient monitoring responsibilities.
- Coordinating with Grant and Contract Accounting on GIM that involve financial policy.
Grant and Contract Accounting
Grant and Contract Accounting (GCA):
- Sets up accounts for spending the award, fiscal compliance monitoring, and the final reconciliation and closeout of an award.
- Prepares financial reports and statements for sponsored programs, as well as federal and state reporting, and prepares claims for reimbursement of expenditures incurred against funding agencies.
University Controller’s Office
The University Controller’s Office (UCO) is responsible for:
- Cash management of sponsored programs, including aged receivables and certain federal and state reporting activities (i.e. Schedule of Expenditures of Federal Awards).
Supplemental Policy
The Office of Research and Grant and Contract Accounting carry joint responsibility for maintaining University policy regarding award management, primarily implemented through GIM. These offices collaborate with other stakeholders to develop policy and guidance.
Refer to the GIM for additional roles and responsibilities related to financial management of sponsored programs.
Policy Statements
1. Pre-Award
The University has institutional responsibility to verify the eligibility of sponsored program proposals submitted to sponsors on behalf of the University. The review and submission of proposals, including the proposal budget, is set out in GIM 1, “Review and Submission Requirements for Proposals.” Authority to approve and transmit proposals to external sponsors on behalf of the institution is outlined in Executive Order No. 34, “Grant and Contract Support of University Activities.”
2. Award Acceptance
Awards are made to the University and not to individuals. Acceptance by the University signifies the University’s willingness to assume responsibility for fiscal management of the award in accordance with the terms specified by the sponsor, applicable federal, state, and local requirements, and University policy.
3. Financial Management
- Assets must be purchased through the University or Harborview financial system of record.
- All purchases must follow applicable University and UW Medicine procurement policies.
3.1. Fiscal Transactions
Fiscal transactions must be completed and posted to the University’s financial system in a timely manner and according to the University’s and GIM (including but not limited to GIM 15, GIM 23, GIM 21, and GIM 39), fiscal internal controls.
3.2. Invoicing, Reporting, and Award Closeout
Grant and Contract Accounting is primarily responsible for submitting sponsor-required invoices, periodic and closeout fiscal reports, and administrative closeout. Unless an exception applies, GCA will work with sponsors to resolve issues so that payment can be remitted. Responsible units must prepare and submit fiscal records and reports as required by GCA.
3.3. Cash Management
The University Controller’s Office is primarily responsible for letter of credit drawdowns, receipt and application of sponsor payments, as well as tracking past due receivables.
3.4. Cost Share
Cost share is discouraged because of the negative effect on resources in other areas of the University, impact to the research base used in calculating Facilities and Administrative (F&A) cost rates, increased audit exposure, and increased administrative burden. The University policy on cost share is established in GIM 21.
Responsible Office and Additional Information
The Office of Research and the Grant & Contract Accounting division of Finance, Planning & Budgeting are jointly responsible for this policy.
History
March 3, 2026.