The role of the Office of Post-award Management (OPM) is to assist departments in monitoring grant expenditures. One procedures that OPM conducts is to reviews all expenditures and ensures that budget exists on the Budget Line item for that expense (Budget Line Item control).
This Budget Line Item checking procedure was put into effect due to the change in December 2014 of the OMB Circulars (Cost Principles and Administrative requirements for federal grants distributed by the Office of Management and Budget (OMB)) to a more “Uniformed Guidance”. One of the most significant changes is in which is the timeframe of award close-outs that reporting MUST BE no later than 90 days after end date of period of performance – submittal of all performance, financial and other reports as required. – OMB 2 CFR 200.343 Closeout. It has been stated by OMB that there will be a stricter adherence to this guideline.
This Budget Line Item checking will better enable the Office of Post Award Management, Office of Finance, and Departments to ensure compliance with the proposed budget award terms, New Uniform Guidance requirements , ease of financial management throughout the life cycle of the award, and the above mentioned award close-out process/45 day policy.
In cases of over expenditure, the PI and department administrator should take immediate steps to eliminate the shortfall within the month after it appears on the Financial Summary Reports. In practice, over expenditures should not continue beyond a three month period.
How OPM manages over expended grants:
- OPM will notify the Principal Investigator and/or department if an over expenditure occurred.
- However, you should not wait until you are notified by OPM of the overdraft to initiate corrective action. If OPM is advised that additional funds are forthcoming within ninety days (either through continuation, renewal, or incremental funding of the award), then the over expenditure can remain in place.
- If additional funds are not expected, then action should be taken to clear the over expenditure before month end. It is a normal course of action for the department to transfer expenses off the grant to another grant as allowable (IDT or ePAR).
- If the PI is unable to resolve or propose a plan to remedy the over expenditure, a notice will be sent to the School Fiscal Officer specifying the project/grant, and amount overspent to request assistance to clear the over expenditure.
- If the over expenditure is still not cleared, an unrestricted department account will be requested by OPM from the School Fiscal Officers to absorb the over expended balance.
Due to unanticipated circumstances, a Principal Investigator may need additional time to complete the project. A request for a no-cost extension must be submitted to the Office of Sponsored Projects (OSP) and should provide such information as cause of delay, objectives to be accomplished, period of extension, and the remaining funding. Please refer to Period of Performance guideline and Office of Sponsored Projects website for further information on No-cost extensions.
Related Policies and Guidance
- Roles and Responsibility