i. Signature Authorization
ii. Electronic Signatures/Approvals
iii. Additional Authorization (One-Up Signature) Policy
iv. Criteria for Determining the Allowability of Expenditures
v. Cost-Transfers, Payroll Redistribution or Reallocation of Charges
vi. Specialized Categories of Expenditures
   a. Hospitality Policy
   b. Computing Devices
   c. Cell Phones
   d. Administrative and Clerical Salaries
   e. Participant Support Costs
   f. Consultant and Independent Contractor Payments
   g. Subagreement Procedures
   h. Scholarship/Fellowship Payments to Individuals

i. Signature Authorization

The PI is responsible for complying with the financial and administrative policies and procedures of each award and has exclusive authority to incur expenses against the award. The PI also has the authority to designate this authority to an SDSU or SDSU Research Foundation staff member to assist in the management of sponsored project(s). This authorization enables an individual to approve requests for personnel actions, to initiate and authorize expenditures including purchase orders for goods and services, to approve reimbursement to individuals for travel, equipment, and all other types of expenditures, and to approve journal vouchers and cost transfers. Signature authority has no set dollar threshold and grants total fiscal responsibility to an individual other than the PI. However, PIs should designate this authority only to staff that are capable of sound fiscal management and have knowledge of administrative policies and procedures. Designees must be an employee of either SDSU or SDSU Research Foundation. Exceptions must be requested in writing and approved by the associate executive director of sponsored research services or the director of sponsored research administration.

ii. Electronic Signatures/Approvals

SDSU Research Foundation utilizes information systems that support electronic transactions, including electronic approvals (e-authorization). Unique accounts (user id and password) are created for individual employees and are for the use of that individual only and must NOT be shared. Use of on-line user ids and passwords in SDSURF systems is the equivalent of a wet ink signature on paper. Individuals shall be liable for all activities on their assigned accounts.

iii. Additional Authorization (One-Up Signature) Policy

The SR grant specialist serves as the one-up approval authority except in specific circumstances defined under the hosting policy and when relevancy to a program is not easily determined. In those cases, one-up authorization would follow the academic chain (i.e. department chair or dean). The primary purpose of a one-up authorization is to ensure that the programmatic purpose of the expenditure has been validated by other than the authorized signer on the fund. This is particularly appropriate and prudent when any authorized signer is submitting a request for reimbursement to herself/himself.

Note: One-up authorization is up the administrative reporting line. One-up authorization cannot be another authorized signer on the fund. For a faculty member or project staff person, it will be the department chair, unless the dean signs. For a department chair, it will be the dean. For a dean, it will be the office of the provost. SDSU Research Foundation will not maintain a list of these administrative levels within each division, college, or department. Project directors and PIs are charged with ensuring that the appropriate authorizations are obtained in the following circumstances:

• Any activity that appears to predominantly benefit the individual or the individual’s relatives. Any expense submitted more than one year after the date the expense was incurred. All expenses should be submitted for reimbursement or payment in a timely manner; typically, within 30 days of incurring the expense. Expenditures and occasions requiring one-up authorizations must be in accordance with SDSURF’s hosting policy (see II.G.Expenditure Processing, 6a.).
• All Campus and Community Relations (CCR) funds expended require approval from SDSU Business Affairs.
• When SDSU Research Foundation determines that the documentation requires more detail and/or explanation in order to meet audit requirements, (e.g., an unclear connection between the activity and the stated benefit to the university), paperwork may be returned for more information and/or one-up authorization. The decision to do so is within the authority of the SDSU Research Foundation sponsored research administration department. If found to be unallowable or not timely, the expense will be the responsibility of the individual who incurred the cost.

iv. Criteria for Determining the Allowability of Expenditures

SR grant specialists are required to apply certain standards to expenditures charged to monies generated by sponsored or restricted funds awarded through grants, contracts, cooperative agreements and other agreements (grants or contracts). Federal 2 CFR Part 220 (OMB A-21) contains the cost principles for educational institutions and applies to awards issued prior to December 26, 2014. Awards issued on or after December 26, 2014 are subject to the Office of Management and Budget (OMB) “Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (2 CFR, Part 200)”. These federal regulations contain the cost principles for the administration of federal awards. Individual award documents may also contain substantive guidelines for determining approval of expenditures, i.e., special terms and conditions applicable to a specific project fund. Expenditure activity must be consistent with sponsor guidelines, San Diego State University’s academic philosophies and institutional objectives, as well as SDSU Research Foundation's overall policies and procedures. Further, expenses must be necessary to the program, submitted in a timely manner, and supported by appropriate documentation as defined further in this section.

In order for a proposed expenditure on a grant or contract to be approved by SDSU Research Foundation, the cost must be allowable, allocable, and reasonable under the federal cost principles outlined in 2 CFR Part 220 (OMB A-21) or 2 CFR Part 200 (Uniform Guidance) as applicable:

1. Allowability: The cost must be reasonable and must be given consistent treatment through application of generally accepted accounting principles appropriate to the circumstances. The costs must conform to any limitations or exclusions set forth in the sponsored agreement or in the Federal Cost Principles (2 CFR Part 220 (OMB A-21) or 2 CFR Part 200 (Uniform Guidance)).
2. Allocability: An expenditure is considered allocable if it is made on behalf of, or in support of, the expressed purpose of the project and is therefore assignable to that project. This means the cost has been incurred specifically to support or advance the work of the sponsored agreement and it is consistent with the scope of work contained in the award document. If costs are to be split among sponsored agreements, they must be in proportions that can be approximated through use of reasonable measures. Costs to a particular sponsored agreement may not be shifted to other sponsored agreements in order to meet deficiencies caused by overruns, other funds requirements to avoid restrictions, or other reasons of convenience.
3. Reasonableness: Finally, a cost is evaluated for reasonableness. A cost may be considered reasonable if the nature of the goods or services reflect the action that a prudent person would have taken under the circumstances prevailing at the time the decision to incur the cost was made. Consideration might include whether or not the cost is of a type generally recognized as necessary for the performance of the agreement and/or if there are restraints or requirements imposed by arm’s-length bargaining. The reasonableness criterion requires that those expending from SDSU Research Foundation funds apply common business sense.

SR grant specialists also review all payment documents and requests for reimbursement with the following principles in mind:

1. Consistency: Transactions must be treated in a consistent manner. SDSU Research Foundation policies have been designed to address similar types of transactions in a consistent manner.
2. Timely Processing of Payment Documents: All requests for reimbursements, personnel appointments and reimbursement for payments to vendors should be submitted within 90 days of their origination. SDSU Research Foundation is subject to federal guidelines that require grantee institutions to demonstrate sound business practices in the management of sponsored funds. The majority of vendors require payment within 30 days of the date of invoice.
   
   2 CFR Part 200.343 OMB Uniform Guidance further states that all financial commitments incurred through the last day of the grant budget period must be processed for payment within the following 90 days. Expenditures submitted after that 90-day window of time may be deemed unallowable. The PI and project staff is responsible for submitting all payment documents in a timely manner to their assigned SR grant specialist. Grant Specialists may request additional justification for payment documents submitted outside of the 90-day window, and additional management review may be required.
3. Justification: There must be sufficient justification showing the expenditure supports the project’s goals and adheres to sponsor and SDSU Research Foundation guidelines.
4. Documentation: Sufficient documentation to support the transaction, such as an itemized, dated receipt, must be included. The documentation should be sufficient to stand alone when reviewed during an audit.
5. Certification: The expenditure document must contain the original signature of the PI or other individual who has been authorized to incur expenses on a specific sponsored agreement. (See Section II. G. Signature Authorization.)

v. Cost-Transfers, Payroll Redistribution or Reallocation of Charges

Cost transfers, payroll redistributions and journal vouchers are transactions that move charges from one fund to another or between line items within a fund. Since there are policies and procedures and internal controls in place at SDSU Research Foundation to ensure that costs are accurately recorded, an original transaction should not need to be corrected. However, in certain circumstances, it may be necessary to move a direct charge expense from one fund to another or within a fund to link the cost more appropriately with the benefit it is providing.

In order to limit the need for cost transfers, payroll redistributions and journal vouchers, PIs are encouraged to work with their SR grant specialist to accurately project expenditures and allocate funds. Monthly budget reports should be used to compare project budgets against expenditures to date and future commitments to determine if overruns will occur. If an overrun is anticipated, the PI should contact her/his SR grant specialist to prepare a cost projection or budget adjustment.

A cost transfer is a direct charge expense transferred from one fund/award to another after the charge has been posted in the financial accounting records of SDSU Research Foundation. Cost transfers include redistributions of payroll expenses as well as the transfer via a journal voucher of other direct costs. The transfer of expenditures between funds awarded under the same grant is not considered a cost transfer. An example of this type of transfer is the correction of expenditures that posted to a prior budget period under the same award, i.e. moving an expenditure from the “A” year to the “B” year of an award. The Cost Transfer Policy is applicable to all funds that SDSU Research Foundation administers.

Policy and Procedure: All requests for cost transfers or payroll redistributions should be submitted in writing to the assigned SR grant specialist and contain the following:

• Documentation: In order for a cost transfer or redistribution of payroll to occur, it MUST be supported by written documentation that contains a full explanation and justification for the transfer. The justification should be prepared in such a way that a person outside of SDSU Research Foundation (i.e., an auditor) would be able to understand why the cost transfer is necessary and should address the following questions:
  
  1. Why was the expense originally charged to the fund from which it is now being transferred?
  2. Why should the charge be transferred to the proposed fund? How does the expense fit the scope of work of the proposed fund?
  3. If applicable, why is this transfer being requested more than 90 days after the cost was initially charged?
  4. What action will be taken to eliminate the future need for cost transfers of this type? Is this action being taken?
• Approvals. A cost transfer or payroll redistribution must have the approval signatures of the PI, the SR grant specialist, an SRA Manager and/or the director of sponsored research administration. Cost transfers or payroll redistributions initiated over 60 days after the fund end date must also have the approval of the director of sponsored research administration.
• Acceptability. Cost transfers and payroll redistributions must be timely, allocable to proper budget categories, allowable under applicable sponsor and SDSU Research Foundation policies, properly documented, and approved. All cost transfers and payroll redistributions shall become part of the official project file and subject to audit. Requests for cost transfers or payroll redistributions that lack adequate documentation and/or approval signatures may be denied.
• Unallowable Cost Transfers. The following cost transfer situations are typically considered to be unallowable:
  1. Cost transfers requested more than 60 days after the end date of a sponsored agreement.
  2. Transfer of charges from any sponsored agreement that is in an overrun status to another sponsored agreement.
  3. Transfer of any reimbursed-time transactions or direct salary payments to faculty where the effort report has already been certified. (All adjustments made to faculty payroll must go through the effort reporting system and should be made before the employee's effort certification is signed and received.)
  Extenuating circumstances will be reviewed on a case-by-case basis and must be clearly and substantially documented.
• Journal Vouchers are utilized for a variety of purposes including but not limited to recording transactions for charge backs from SDSU recharge centers, internal transfers of cash between SDSU Research Foundation funds, and corrections to elements of the accounting string associated with a revenue or expenditure transaction, including the Fund, Organization, Account and Program. Please submit requests for Journal Vouchers to your SDSU Research Foundation SR grant specialist or fund administrator.

vi. Specialized Categories of Expenditures

The purpose of this section is to identify costs that require more substantial documentation or that have unique policies or procedures associated with the approval process. Please refer to Section 3. Purchasing and Section 4. Accounts Payable and and Section 5. Travel for additional information.

1. Hospitality Policy
   Hospitality expenses may be paid with SDSU Research Foundation funds when such expenses are necessary, appropriate to the occasion, reasonable in amount and serve a purpose connected to the mission and fiduciary responsibilities of San Diego State University and/or the Research Foundation. This policy applies to activities that promote the university/SDSU Research Foundation to the public and the provision of hospitality in connection with official university/SDSU Research Foundation business and authorizes appropriate Research Foundation funds to be used for such purposes. The policy is written to be consistent with university and CSU policies and procedures.
   
   Hospitality expenses may not be charged to grants and contracts (5 ledger funds) unless the expense has been approved by the sponsoring entity.
   
   Please review the detailed information on the allowable expenses and occasions, documentation requirements and maximum per person reimbursement rates outlined in the hospitality policy prior to incurring costs. The hospitality policy is available at: https://www.foundation.sdsu.edu/pdf/sra_hospitality_policy_2024.pdf. (PDF Format, 233KB)*
   
   
2. Computing Devices
   Computing devices and accessories (or “peripherals”) for printing, transmitting and receiving or storing electronic information costing under $5,000/unit may be direct charged to a project if:
   
   
   • They are essential and allocable to the project in that they are necessary to acquire, store, analyze, process and publish data and other information electronically and;
   • the project does not have reasonable access to other devices or equipment that can achieve the same purpose; devices may not be purchased for reasons of convenience or preference.
   
   Items costing more than $5,000/unit are considered equipment and subject to policies and procedures specific to equipment purchases.
   
   PIs are encouraged to specifically budget for computing devices and include a detailed explanation of the essential nature of the items at the proposal phase of the award. If not specifically budgeted, the PI is responsible for providing this information to his/her SRA grant specialist prior to the cost being incurred to ensure the purchase meets federal agency and award specific requirements.


3. Cell Phones
   Direct Charging on Sponsored Agreements
   Federal regulations state that telephone costs are typically unallowable as a direct cost on a grant; however, direct charging of these costs may be appropriate if the use of a cell phone is essential and allocable to the project, the item is specifically budgeted for and approved by the sponsor agency. Please contact your grant specialist with questions regarding allowability and award specific terms regarding this type of cost.
   
   The project should submit a Request to Direct Charge Cell Phone Expenditures to a Sponsored Project form to the SRA grant specialist prior to incurring costs. Sponsor approval may be required if the costs were not specifically budgeted for and approved by the funding agency at the proposal stage.
   
   Due to the unique characteristics of each sponsored project, the director of sponsored research administration will review and approve requests to direct charge cell phones or other wireless communication devices on a case-by-case basis.
   
   SDSU Research Foundation-Owned Cell Phones
   In rare and unusual circumstances SDSU Research Foundation will provide foundation-owned cell phones. These circumstances may include specific programmatic requirements of sponsored research activities. In these instances, the following criteria apply:
   
   
   • These cell phones are for business use only by the assigned employee exclusively and may not be used for personal calls.
   
   
   • Justification for the purchase and business use of a cell phone will be submitted to SDSURF Procurement with the requisition for the acquisition of the device and establishment of the appropriate level of service.
   
   
   • The cell phone will be tagged as SDSU Research Foundation property and will be subject to SDSURF’s equipment inventory procedures. The device must be returned if the employee leaves the organization, or if there is no longer a programmatic need for the device.
   
   
   • Issuance of the device to the employee will be documented on an Off-Campus Use of Equipment Agreement Form. A memo must be attached to the form thoroughly explaining why a research foundation-owned phone is required. Additional documentation addressing reasonableness, allowability and allocability is also required for charges to grants and contracts. Refer to www.foundation.sdsu.edu/doc/sra_wireless_req_rev.doc
   
   
   • Monthly statements will be reviewed and approved by the employee’s authorizing individual, regardless of method of payment.
   • All records will be retained in accordance with SDSU Research Foundation’s record retention policies and are subject to public disclosure in accordance with the McKee Transparency Act.
   
   Cell Phone Allowances:
   The vast majority of employees use a cell phone for personal purposes; however, employees in certain safety and management positions must be accessible after hours and when away from their primary business location during the regular work day. These employees may receive an allowance for the percentage of cell phone use that relates to SDSU Research Foundation business. Cell phone allowances may not be charged to sponsored programs.
   
   The employee’s supervisor will identify the need and extent of the allowance. The authorizing individual as defined in the Applicability section below will approve the allowance.
   
   
   • Employees must comply with McKee Transparency Act and public records requests related to SDSU Research Foundation business. The act may be accessed at:
     www.leginfo.ca.gov/pub/11-12/bill/sen/sb_0001-0050/sb_8_bill_20110714_amended_asm_v95.pdf  
   • Employees may decline an allowance.
   • Allowances will not be provided for wireless devices or other related equipment.
   • In the interest of the safety of our employees and other drivers, cell phone use while driving on research foundation business and/or research foundation time is prohibited. If the employee’s position requires that the employee keep a cellular phone turned on while driving, the employee must use a hands-free device. Law prohibits any persons under the age of 18 from using any mobile device while driving, except for emergency purposes.
   • Writing, sending, or reading text-based communication – including text messages, instant messaging, and e-mail is prohibited by law and policy.
   • •Employees should safely pull off the road before conducting research foundation business while using mobile devices.
   
   Applicability: This process applies to SDSU Research Foundation employees who are required to carry a cell phone to be available while away from campus and/or as a necessary and integral tool in performing their assigned duties.
   
   The determination of whether an employee is required to be available via cell phone is decided by his or her authorizing individual. For purposes of this policy the authorizing individual is defined as an individual with delegated fiscal authority on the fund to which the allowance will be charged. For individuals who have delegated fiscal authority and are requesting approval for their own cell-phone, the named project or fund manager will be the authorizing individual. If the request is for a faculty member, the authorizing individual will be the department chair or the dean. For a department chair, it will be the dean and for a dean, it will be the office of the provost. Other units will follow the university organizational hierarchy for their respective areas. In no case may an individual authorize her or his own request.
   
   The following criteria are used to determine applicability:
   
   
   • The authorizing individual must articulate substantial non-compensatory business reasons for requiring the employee to use the cell phone for work-related purposes.
   • The employee must maintain the type of cell phone coverage that is reasonably related to the needs of SDSU Research Foundation’s business,
   • The employee must not already receive a reimbursement from the university, and
   • The policy applies to cell phones as well as data plans for other similar wireless communication devices; however, only service charges for cell phone usage are eligible for reimbursement.
   
   Authorization for Business-Related Cell Phone Form: The authorizing individual must complete an authorization form that provides a justification for providing a cell phone allowance, the type of cellular service to perform job duties (voice, text and/or data), the expected required percentage of business use, and other specific information concerning the required usage. The form is available at: www.foundation.sdsu.edu/forms/index.html#purchasing
   
   Compliance with Tax Law: Allowances for employee-owned cell phones that are used for business purposes are non-taxable if an appropriate level of substantiation is made to SDSU Research Foundation.
   
   Guidelines: All cell phones are the personal property of the employee. Changes in service for personal use are the employee’s responsibility. In addition, the employee will retain the phone number and instrument if he or she separates from the organization.
   
   The expense allowance for service charges is generally tax-free and will be issued through Accounts Payable on an annual basis. Exceptions are rare and approved on a case-by-case basis.
   
   The employee retains the allowance payment and is not obligated to refund SDSU Research Foundation if the employee separates, changes job duties, or transfers to a new position within the calendar year.
   
   SDSU Research Foundation will provide expense allowances toward service fees only. The allowance amount is determined by the authorizing individual, based on his or her estimate of the amount of expected SDSU Research Foundation-required business usage. The estimate will be based upon past, comparable or expected wireless usage for the employee’s position. The authorizing individual may not use this expense allowance as a salary supplement. If the employee disagrees with the allowance amount, he or she may propose an alternative allowance to their authorizing individual and must provide evidence to substantiate the higher amount.
   
   The SDSU Research Foundation-paid allowance is used to defray the cost of the use of the cell phone for SDSU Research Foundation business. Upon request, the employee shall make available records of business calls, as necessary to comply with applicable laws and regulations, including but not limited to the McKee Transparency Act, if readily available. The employee may redact any personal information from the records provided. The employee agrees to retain cell phone bills for thirty (30) days from the date of receipt of said bills by the employee.
   
   As long as the wireless service provider’s plan supports and is compatible with the use required to accomplish SDSU Research Foundation job responsibilities, the employee may choose the device and the service plan he or she wishes to use. The arrangement is between the employee and the wireless service provider; SDSU Research Foundation is not involved in the contract with the provider. However, the employee is encouraged to consult with SDSU Research Foundation’s purchasing department to determine what discounts are available to employees prior to purchasing a device and selecting a service plan.
   
   Monthly Service Charges: An annual expense allowance toward service fees will be paid to the employee based upon the actual cost of her or his service plan. The employee is required to attach to the authorization form, a copy of her or his monthly service plan statement and a certification to the effect that it is representative of what she or he will be paying in the succeeding 11 months.
   
   The percentage reimbursement varies by position and job responsibility and may range from 10% to 75%.
   
   In no case shall the reimbursement exceed the actual cost of the service fees actually incurred.
   
   SDSU Research Foundation prepares an annual cost analysis. These rates are the maximum basis for any allowance. The following maximums apply for calendar year 2015:
   
   Unlimited Voice and Text - $780 per year or $65 per month
   Unlimited Voice, Text and Data - $1,100 per year or $92 per month
   
   The table below is provided as an example of the basis for a reimbursement plan.
   
   Annual Reimbursement by Required Usage Level
   
   

   Plans	Annual Cost with Employee Discount	Low-level User (10%)	Mid-level User (50%)	High-level User (75%)
   A - Unlimited Voice & Text	$780	$78	$390	$585
   B - Unlimited Voice, Text & Data	$1,100	$110	$550	$825

   
   Renewal Cycle: By default, employee wireless allowances will be paid on an annual/calendar year basis. Other payment cycles will be made on an exception basis only.
   
   Renewal Amount: The authorizing individual and employee will review the basis for the allowance amount at each renewal period and provide an updated justification and a current service plan monthly statement at each renewal cycle.
   
   Interim adjustments: Interim adjustments may be required. Examples of adjustments include: underestimated usage, change in job duties requiring change in usage, changes to increase features/access new technology at the direction of the authorizing individual, termination of employment or other similar circumstances.
   
   
   • Monthly statements will be reviewed and approved by the employee’s authorizing individual, regardless of method of payment.
   • All records will be retained in accordance with SDSU Research Foundation’s record retention policies and are subject to public disclosure in accordance with the McKee Transparency Act.
   • Questions related to funding sources and allocations should be directly to the user’s supervisor or SR grant specialist.
   
   
4. Administrative and Clerical Salaries
   Federal regulations state that the salaries of administrative and clerical staff should normally be treated as indirect (F&A) costs on sponsored agreements. However, direct charging of these costs may be appropriate only if all of the following conditions are met:
   
   
   • Administrative or clerical salaries are integral (i.e. essential, vital or fundamental) to the project or activity
   • Individuals involved can be specifically identified with the project or activity
   • Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and
   • The costs are not recovered as indirect (F&A) costs.
   
   To facilitate sponsor approval, PIs are encouraged to specifically budget for these costs and include a justification statement that addresses the criteria under items 1 and 2 in the proposal document. If new or additional (over 25% of the amount previously approved) administrative or clerical support is needed during the life of the award, sponsor approval must be obtained in writing before any costs are incurred. The SRA grant specialist will work with the PI to obtain prior approval from the sponsor agency.


5. Participant Support Costs
   Participant support costs include stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences or training projects. These costs are not routinely allowed on research projects but can be charged if the project includes an education or outreach component and the agency approves such costs.
   
   Federal regulations (2 CFR 200.456) state that participant support costs are allowable with the prior approval of the sponsor agency. Participant support costs should be explicitly listed in the proposal budget and budget justification. After an award has been made, requests to add new participant support costs line items to the budget or make changes to existing line items require prior written approval by the funding agency.


6. Consultant and Independent Contractor Payments
   PIs frequently use consultants to perform specific tasks when specialized skills or expertise is not available internally. A variety of different legal standards is used to determine whether or not an individual is an employee or an independent contractor. The post-award staff in sponsored research administration work with the associate director of human resources to assist the PI in applying these standards to ensure the individual is paid appropriately.
   
   Before an individual is retained as a consultant or independent contractor, the PI should complete an Independent Contractor Pre-Selection Checklist and forward it to his/her grant specialist. The SRA grant specialist will review the form and forward to the associate director of HR for approval.
   
   Please note that any consultants that are also CSU employees require additional review and may be required to be paid through payroll. See Evaluating Independent Contractor vs. Employee Status. for more information.
   
   Some consulting arrangements may require a consultant agreement in addition to the independent contractor form. A consultant agreement is a contract with an individual rather than an organization that contains specific contractual language concerning task oriented timelines, payment methods and cancellation clauses. The agreement also includes a scope of services, required deliverables, and a budget and/or payment schedule.
   
   The consulting agreement can be initiated any time the PI or the SRA grant specialist determines that tighter controls are required due to the dollar amount of the agreement, the time period of the agreement, or the nature of the work and/or deliverables. Each independent contractor form with a dollar threshold of $5,000 or greater, and/or a specified contract period of greater than three months, is to be reviewed to determine if a consultant agreement is necessary.


7. Subagreement Procedures
   A subagreement is an agreement issued to an external organization under a prime award received by SDSU Research Foundation. The subagreement authorizes a portion of the project activity to be performed by another organization. The word “subagreement” will be used throughout this section to refer to all types of subagreements including collaborative agreements, subagreements, subawards, subcontracts, memorandums of agreement, memorandums of understanding and other third party agreements. The subagreement document outlines the rights and responsibilities of each party.
   
   At the proposal stage, the PI determines whether he/she will be collaborating with another institution to complete the proposed scope of work. The SR development office will review the subagreement materials as well as the full proposal before submitting the proposal to the sponsor. SR development will also ensure that the subrecipient institution has reviewed and approved its portion of the proposal and has submitted a budget and scope of work along with any required institutional assurances to be included in the SDSU Research Foundation proposal. SR development will work with the subrecipient institution to obtain necessary approval for collaboration with the SDSU PI, ensure the budget is adequate to support the scope of work, and verify the authorized institution official has endorsed the subagreement proposal. If a subrecipient is named on a final sponsor-approved budget and no other restrictions are included in the award document, the subrecipient is considered approved. Note: Some agencies require additional sponsor review and approval of the final subagreement document, even if the subrecipient institution is named in the proposal. If there is a need to issue a subagreement for a portion of the work, but no subrecipient was indicated in the proposal, the SRA grant specialist must secure sponsor approval before a subagreement can be finalized. Prior sponsor approval protects the interests of SDSU Research Foundation and the university. Without prior sponsor approval, the sponsor has no responsibility to reimburse subagreement costs.
   
   In order to issue a subagreement for the procurement of goods or services (as opposed to work to be performed), the project must follow a process of solicitation, selection and award. A request for proposal (RFP) will be developed by the PI and the SRA grant specialist using the scope of work provided by the PI. The goal is to receive a minimum of three responses to the solicitation. Upon selection of a subrecipient, SDSU Research Foundation will negotiate, prepare the subagreement, and finalize the arrangements.
   
   Overview of the Subaward Process:
   
   
   • The PI should contact her/his SRCC analyst to initiate the issuing of a subagreement.
   • The SRCC analyst works with the SRA grant specialist during the preparation of the subagreement. The SRCC analyst is primarily responsible for corresponding with the subrecipient to ensure that compliance issues are met. The SRCC analyst will confer with the PI and/or the SRA grant specialist to ensure that reporting and invoicing are in accordance with the prime award.
   • The SRCC analyst will forward a Disclosure of Financial Interest form for the PI to complete and return. The SRCC analyst will request the name of the subrecipient PI and an administrative contact if this information was not included in the proposal document.
   • The SRCC analyst will determine if the proposed subrecipient institution is currently approved with current financial statements and certificates of insurance on file with SDSU Research Foundation. If needed, the SRCC analyst will request these items from the subrecipient institution.
   • SDSU Research Foundation's finance and accounting manager must review and approve subrecipients based on her/his review of the recipient’s A-133 audit or financials before a subagreement will be issued.
   • The finance and accounting manager will identify high-risk sub- awardees and may impose additional restrictions on documentation requirements. Risk assessment includes review of financial statements and A-133 or Single audit findings, type and size of the organization, amount of the subagreement and adequacy of the organization’s financial systems.
   • The SRCC director also assesses risk in completing a restricted party screening (review to exclude entities that are debarred, suspended or otherwise restricted from receiving funding) at the initiation and prior to fully executing the subagreement. Additional review is performed to determine whether additional restrictions should be imposed including subrecipient’s knowledge of sponsored programs administration requirements, potential compliance issues, cost-sharing requirements, and previous history with subrecipient. If needed, the SRCC director will also collaborate with the SR Administration director
   • The SRCC analyst will contact the PI and/or the SRA grant specialist to obtain/verify budget information, scope of work, reports or deliverables that will be required from the subrecipient. The SRCC analyst will work with the SRCC director to prepare the subagreement and forward it to the PI and the SRA grant specialist for approval. Upon approval, the subagreement is then transmitted to the subrecipient for review and approval.
   • If the subrecipient does not request modifications, the subagreement is partially executed and returned to the SRCC director to fully execute. If the subrecipient institution requests revisions, the SRCC analyst will work with the SRCC director and the subrecipient on the requested modification. Negotiations take place until all parties are in agreement on the terms and conditions of the subagreement.
   • Once the fully executed subagreement is in place, the SRCC analyst encumbers the funds and provides a copy of the fully executed subagreement to the subrecipient and the SRA grant specialist.
   
   
   The SRA grant specialist is responsible for subrecipient monitoring and serves as the point of contact for any problems associated with the subagreement. Subrecipient monitoring may include requests for budget adjustments, supplemental funding (carryover), and no-cost extensions. The subrecipient submits invoices as frequently as monthly directly to SDSU Research Foundation's accounts payable department. This department forwards the invoice to the PI for review and signature approval. The PI reviews and approves the invoice. The PI’s approval includes a certification that the work is progressing satisfactorily and all technical reports and/or deliverables due have been received. The PI should notify the SRA grant specialist of any concerns with the progress or deliverables associated with the subagreement. Approval of the invoices may be held at the PI's request pending satisfactory performance. The SR grant specialist will review and authorize the subrecipient’s invoice/financial report for payment. Unless the subrecipient has been designated as a “high-risk sub awardee” supporting documentation for the subrecipient’s invoice/financial report is generally not required. The payment authorization form is forwarded to A/P for processing.

Subrecipient Monitoring:
SDSU Research Foundation is ultimately responsible for every compliance aspect of the project, including the subagreement portion. SDSU Research Foundation’s obligation to the sponsor agency does not change if the subrecipient has unsatisfactory progress or defaults.

PIs are responsible for acting as the technical monitor of the subagreement and overseeing the performance of the subrecipient to ensure satisfactory completion of the scope of work. This includes:


• Monitoring the subrecipient's technical and programmatic activities as they relate to the subagreement.
• Reviewing subrecipient's technical/performance reports as required.
• Verifying subrecipient has completed the scope of work in both a timely and satisfactory manner.
• Reviewing and approving invoices submitted by the subrecipient. This includes reviewing expenditures to ensure they are appropriate for the work being performed and in accordance with the terms and conditions of the subagreement.
• Maintaining regular contact with the subrecipient.
• Notifying the SR grant specialist of any concerns with the subrecipient's performance or spending.
• Working with SR Administration and the subrecipient to resolve any issues identified.

SR Administration is responsible for subrecipient monitoring in accordance with federal requirements, award specific terms and conditions and research foundation policies and procedures. This includes:


• Reviewing subrecipient invoices to ensure costs are allowable, allocable and reasonable, and are appropriate for the approved budget and the terms and conditions of the subagreement.
• Ensuring that subrecipient invoices are approved by the PI or his/her designee and submitted in a timely manner.
• Requesting additional information or source documentation from the subrecipient if invoices contain costs that are questionable or insufficiently detailed.
• Working with PIs to resolve any concerns reported. Resolution of significant concerns may involve the PI, SR Administration, SR Contracting and Compliance and the subrecipient. Actions taken by SRA will be based on the individual situation and may include performing a desk audit, requesting and approving a subrecipient corrective action plan, additional monitoring of subrecipient's progress and follow-up action for non-compliance.


8. Scholarship/Fellowship Payments to Individuals
   Scholarship/Fellowship disbursements can only be issued to individuals who are not being required to perform any past, present, or future services in exchange for the payment. Individuals participating in activities warranting the payment of scholarship or fellowship funds will have been selected for participation in conjunction with the eligibility requirements associated with the project award guidelines. The disbursement of funds to an individual may cover books, equipment, fees, living expenses, supplies and/or tuition required for courses or instruction or participation in project activities.
   
   The receipt of scholarship/fellowship funds can affect a student’s eligibility for financial aid. The SDSU Office of Financial Aid and Scholarships reviews payments made to students by SDSU Research Foundation and uses this information to determine the allowable amount of financial aid for each affected student.
   
   Individuals receiving payment under the above circumstances will complete the Notice to Recipients of Scholarships and Fellowships. If the individual receiving payment has applied for or has been awarded financial aid, approval from the SDSU Office if Financial Aid is required prior to any payments being issued from SDSU Research Foundation. The form is located at: www.foundation.sdsu.edu/doc/ap_fa_schol_fellow.docx.
   
   The Internal Revenue Service does not require SDSU Research Foundation to report taxable fellowship and scholarship income to either the individual or the IRS. It is entirely the responsibility of the U.S. citizen or resident alien to report any taxable income on her/his tax return. If the recipient has any questions, it is recommended that they engage a tax professional.

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