TSU Office of Institutional Compliance

Grants Management Review Process

WHAT OCCURS ON A ROUTINE COMPLIANCE REVIEW

Scheduling

To the extent possible, the Office of Institutional Compliance will provide prior notice of the upcoming review. One exception is a review involving potential fraud or abuse, which is not subject to prior notice.

Planning

The Compliance Officer assigned to conduct the review will research applicable policies and regulations. Each compliance review will include a program that details the procedures and components to be analyzed. The compliance review documentation will provide specific program procedures and analysis supporting findings, if applicable.

Fieldwork

The fieldwork will begin with a review of the history of the grant and will include an analysis of departmental reports. Interviews may be conducted with grant employees to inquire and validate their duties. The Compliance Officer will seek to minimize the demand on others by performing majority of the work within the Compliance office. The three major areas of the compliance review will include: 1) grant award, 2) grant expenditures and 3) reporting.

Grant Award - The grant award provides the basis for the compliance review. The award provides the name of the external agency, performance period, award amount, funding amount and period. In addition, the grant award outlines the various rules and regulations that must be adhered to remain in compliance with the granting agency.

Expenditures - The expenditures are reviewed to ensure the allowability and allocability of the cost expended during the funding period. Salary and wage expenditures, as well as other expenditures such as stipends, consulting, equipment purchases, travel, supplies, books, hardware and software purchases, are examined in detail for adherence to grant requirements. In addition to the granting agency requirements, the expenditures are also reviewed for adherence to applicable federal and or state requirements.

Reporting - As a recipient of grant funds, TSU is responsible for providing routine reports regarding various aspects of the grant. Quarterly, the Principal Investigator should submit Time and Effort Reports to the Office of Sponsored Programs. In the event the end of a quarter falls on a weekend or holiday, the report will be due the next business day. Technical and programmatic reports, which are completed by the Principal Investigator, are maintained in the Office of Sponsored Programs (OSP). The OSP is responsible for ensuring the reports are completed and confirms the reports were forwarded to the appropriate agency. Financial reports are compiled by the Office of Grants and Contracts and forwarded to the required agency. Copies of the financial reports should be maintained in the Office of Grants and Contracts.

Communication

Following fieldwork, the Compliance Officer will prepare a final memorandum to the Principal Investigator and senior management. The memorandum will include review findings and detail of the work performed and issues to be resolved. In addition, the Principal Investigator will review the memorandum and provide their signature indicating they have reviewed all information.

Response

The Principal Investigator or senior management should provide the Office of Institutional Compliance a written action plan to address the findings and recommendations in the final report within twenty (20) business days.

Follow-up

The Office of Institutional Compliance will conduct a follow-up review to evaluate the effectiveness of the action steps taken and ensure the desired results are operative.