Our institution was in a similar situation a year ago.  The auditors found that there were insufficient controls for grant expenditures, and I agreed with them (which was easy since I was a newcomer).  At this PUI, professors' expenses are approved by their department head.  Most of the people with grants are department heads, and no one was approving their expenses on grants.  The department heads report to the VP of Academic Affairs, who is currently an interim appointment.  In response to the audit, the Board of Trustees voted that the VP of Academic Affairs will approve all grant expenditures for the College (from the perspective of allowability and allocability).  The VP delegated that function to the Research Office (me).

If a professor orders a pencil to be paid for with grant funds, I sign the purchase order.  This has added a layer of work for me, of course.  I am expected to be cognizant of A21 and A133, EDGAR, and any other pertinent policies or regulations.  At a larger institution, it would take a whole staff to do this.  With only $3M in grants, I can cope.  I am finding faculty more cooperative now that they can't spend their money without my OK.

Landy

__________________________
Landy C. Johnson, MPA, Ph.D.
Director of Grant Development
Assumption College, Alumni Hall 024
500 Salisbury St.
Worcester, MA  01609-1296
(508)767-7666
xxxxxx@assumption.edu
http://www.assumption.edu/research

-----Original Message-----
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Date:    Fri, 27 Oct 2006 09:18:59 -0400
From:    Linda Manley <xxxxxx@MUOHIO.EDU>
Subject: PI review of circulars

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Hello:
We are currently having discussions with our auditors regarding an
A-133 comment. In this instance, even though the only expenditures
for the grant were equipment related, and approved by the agency
(grant has since closed and we have written letter from agency
stating all terms and conditions of the grant were met), the auditors
felt that the PI should have formally compared the equipment
expenditures against OMB Circular A-21.  They also feel that we
should monitor all PI's on a periodic basis to ensure that the formal
review of both A21 and A-133 compliance is met. My questions to all
of you: How do other universities educate the PI's on the
requirements of Circular A-133 & A-21? And how do you verify or prove
that the PI is actually comparing expenditures to Circular A-21
allowable/unallowables. Any feedback would be greatly appreciated. Thanks.

"You must give some time to your fellow man. Even if it's a little
thing, do something for others - something for which you get no pay
but the privilege of doing it." - Albert Schweitzer

Linda Manley
Grants & Contracts Coordinator
Miami University
Grants & Contracts Department
7 Roudebush Hall
Oxford, OH 45056-3653
(513) 529-5405- work phone
(513) 529-0441 - fax

 **************

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