Funding agencies have delegated to grantee organizations increasingly expanded authority to approve certain administrative actions. These agencies require that grantees assure that there are adequate institutional reviews and approvals of decisions affecting the management of federally supported projects and all approvals must be documented. To provide these assurances, Middlebury College has established an "organizational prior approval system."
The Controller's office is responsible for administering all external funding that comes to Middlebury College and will be governed by OMB Circular A-21, all applicable federal regulations, Middlebury College policies, and the particular grant provisions and conditions of the sponsor. "Authorized Institutional Officials" include the Treasurer, the Assistant Treasurer & Controller, and the Assistant Controller who is "authorized to sign all research grant applications on behalf of the college" (as per the Middlebury College Handbook). The Grants Accountant has day-to-day responsibilities for accounting related to sponsored activities.
Middlebury College has developed a document titled "Post Award Procedures" to provide guidance for faculty and staff who administer grants. These procedures are available on the Middlebury College website and are provided to each Principal Investigator when a grant account is established.
Principal Investigators or Project Directors are authorized to make charges to their grants in accordance with the approved budget. Principal Investigators or Project Directors must consult with the Grants Accountant before incurring any charges that deviate from the awarded budget. The Grants Accountant will approve such expenditures if the following conditions are met:
1) expenditure is allowable under Circular A-21;
2) expenditure is consistent with the terms and conditions of the award and with the policies of the sponsor and Middlebury College;
3) expenditure does not constitute a change in project scope; and
4) expenditure is reasonable, necessary and allocable to the project.
Principal Investigators or Project Directors requesting administrative changes (including expenditures or other actions that require prior agency approval, no-cost extensions of grant period, incurring costs prior to the beginning of an award, or budget revisions that involve transfer of funds among budget categories) should submit a "Prior Approval Request Form" (OPAS Form) to the Coordinator of Sponsored Research who will obtain any additional required signatures. If the granting agency has authorized the College, as grantee, to approve such changes then the Assistant Controller will approve the request if the following conditions are met:
1) any expenditures are consistent with the four conditions outlined above;
2) the change is consistent with the terms and conditions of the award and with the policies of the sponsor and Middlebury College;
3) the change does not constitute a change in the scope of the project.
If the College does not have the authority to approve the request, the Assistant Controller will forward the request to the funding agency.
The signed OPAS Form will be retained in the grant file as written documentation of the approval for three years following the submission of the final financial report.
Updated: 5/7/02