Administration of Grants and Contracts in Support of Sponsored Programs Policy

Reviewed By: Administrative Council on September 13, 2004

Approved By: Albert K. Karnig, President on October 11, 2004

Reviewed By: Administrative Council on March 26, 2026

Approved By: Tomás D Morales, President on April 07, 2026

For interpretation of this policy, please contact the Office of Academic Research, (909) 537-3064

Policy:

This administrative policy implements the requirements of CSU ICSUAM Section 11000 (Integrated CSU Administrative Manual) and supersedes all prior CSUSB policies on sponsored programs. It applies to all sponsored program proposals and awards applied for, received by, or administered through California State University, San Bernardino (CSUSB) and its auxiliary organization, University Enterprises Corporation (UEC at CSUSB). The CSUSB is committed to full compliance with 2 CFR 200 (Uniform Guidance) and all other applicable federal and state regulations, CSU system policies, and sponsor requirements in the administration of grants and contracts.

1. Definitions

1.1 “Auxiliary”: An organization affiliated with the CSUSB that (a) appears on the Chancellor’s list of approved auxiliary organizations in good standing pursuant to 5 CCR §42406, and/or (b) meets the definition in California Education Code §89900 (using the CSUSB’s name, enjoying an official relationship with the CSUSB, or having CSUSB officials on its board by virtue of their position). In the context of this policy, Auxiliary refers to the University Enterprises Corporation (UEC) at CSUSB.

1.2 “Contract”: A binding agreement between the CSUSB or an Auxiliary and a Sponsor to provide an economic benefit (usually services or deliverables) in exchange for compensation. A Contract creates a quid pro quo relationship with specific obligations for both Sponsor and Recipient.

1.3 “Grant”: A financial contribution from a Sponsor to the Recipient to carry out an approved project or activity. A Grant typically does not require substantial programmatic involvement of the Sponsor during the project, though the Sponsor may require financial or performance reports. The CSUSB and/or Auxiliary may commit certain resources or services as a condition of the Grant.

1.4 “Principal Investigator (PI)” (or Project Director): The individual designated by the Sponsored Program Administrator to direct a sponsored project. The PI is responsible for day-to-day management of the project and for compliance with all academic, scientific, technical, financial, and administrative requirements of the Contract or Grant.

1.5 “Recipient”: The entity legally receiving a Contract or Grant – either the CSUSB or an Auxiliary, as specified by the award. The Recipient is never an individual person, department, or other sub-unit, even if a particular college or unit is named in the award document.

1.6 “Sponsor”: The external party or funding agency that funds the project – for example, a federal or state agency, municipality, corporation, foundation, or individual providing the grant or contract funding.

1.7 “Sponsored Program”: Any externally-funded project, program, scholarly activity, or research carried out under a Grant or Contract funded by a non-CSU source. (This includes grants or contracts from non-CSU sponsors that are subcontracted through another institution.)

1.8 “Sponsored Program Administrator”: The entity (either the CSUSB or the Auxiliary) designated by the Recipient to administer the sponsored program. At CSUSB, the Sponsored Program Administrator is typically the Auxiliary (UEC at CSUSB) for most externally-funded projects, in coordination with the CSUSB’s Office of Academic Research.

1.9 “Sponsored Program Records”: All documentation and files related to a sponsored program. This includes (but is not limited to) approved proposals and applications; fully-executed Contracts or Grant agreements and any amendments; budget documents and financial records (invoices, receipts, ledgers); technical and progress reports; human resources and payroll records for project staff; correspondence with Sponsors; and any other records concerning the receipt, review, award, management, and closeout of the Sponsored Program.

1.10 “Sponsored Program Work Product”: Any tangible or intangible work output created in the performance of a sponsored program. Note: Unless stated otherwise in the Contract/Grant, Sponsored Program Work Product does not include scholarly works such as journal articles, books, lectures, or artistic works that are developed through independent academic effort based on the findings of the project – those are typically covered by CSUSB intellectual property policies.

1.11 “University or CSUSB”: California State University, San Bernardino (CSUSB), including any of its colleges, departments, centers, and the Chancellor’s Office when acting on behalf of the campus.

2. General

Sponsored program activity encompasses research, instruction, public service, and other externally-funded scholarly or creative endeavors that are proposed to or funded by outside Sponsors (federal, state, local, corporate, non-profit, or other). When such projects involve the use of the CSUSB’s name, resources (facilities, equipment, or staff time), or imply CSUSB endorsement, CSUSB approval and oversight as described in this policy are required.

2.1 Presidential Responsibility

In accordance with CSU policy (ICSUAM §11000), the CSUSB President is responsible for ensuring that CSUSB and its Auxiliary operate in compliance with all applicable laws, regulations, and CSU/campus policies in the solicitation, acceptance, and administration of Sponsored Programs. The President (or designee) shall establish clear assignments of responsibility to specific campus officials to guarantee coordination between units (CSUSB and Auxiliary) involved in sponsored programs administration. This includes designating officials responsible for pre-award review, post-award financial administration, research compliance, and other facets of sponsored programs management.

2.2 Written Policy Requirement

CSUSB shall maintain a written policy on the administration of grants and contracts (this document) that addresses all required components outlined in CSU ICSUAM §11000. This policy is aligned with other CSUSB policies on risk management, environmental health and safety, conflicts of interest, research misconduct, and any other applicable CSU or campus requirements. In the event a particular sponsored award includes terms more restrictive than those in this policy (without creating a direct conflict), the more restrictive terms of the Sponsor’s award will take precedence.

2.3 Internal Controls

CSUSB and UEC at CSUSB will establish and maintain effective internal controls over sponsored program operations, in accordance with 2 CFR 200.303. These controls are designed to provide reasonable assurance that the CSUSB and Auxiliary comply with all laws, regulations, and award terms. Internal controls include written procedures and systems to: ensure proper financial stewardship of funds, prevent and detect fraud or misuse, maintain segregation of duties in fiscal tasks, and uphold high standards of accountability in every aspect of grant administration. The CSUSB and Auxiliary shall periodically review and strengthen internal controls (following guidance such as “Standards for Internal Control in the Federal Government” and COSO framework) to address any identified weaknesses and to include considerations such as cybersecurity of sponsored program data as required by updated federal guidance.

3. Pre-Award Administration

This section outlines procedures for developing and submitting proposals for sponsored programs and the requirements for official acceptance of awards. All CSUSB faculty or staff seeking external funding must adhere to these pre-award requirements to ensure institutional approval and compliance.

3.1 Proposal Preparation and Planning

Before developing a formal grant or contract proposal, a prospective Principal Investigator (PI) or Project Director should consult with their department chair or immediate supervisor about the planned project – especially regarding how the project will impact the department’s resources and obligations. Early communication should address issues such as:

Workload and Release Time: Will the project require reassigned time (release time) for faculty, and if so, how will the department cover the faculty’s teaching or other duties? Any proposed faculty release time must follow the CSUSB’s Policy and Procedures for the Reimbursement of Faculty Release Time (FAM 603.3) to ensure the department or college is reimbursed at the appropriate rate for the faculty member’s time.
Additional Employment or Overload: Will any faculty or staff receive additional compensation from the grant (beyond their regular appointment)? All additional employment for faculty on a sponsored project must comply with the CSUSB’s Guidelines and Procedures on CSUSB-Compensated Faculty Additional Employment (FAM 603.4) and CSU Additional Employment Policy, which place limits on overload assignments. Generally, full-time faculty/staff can only accept extra pay within prescribed limits to ensure their primary duties are not adversely affected.
Cost Sharing/Matching Commitments: If the proposal includes any commitment of CSUSB and/or Auxiliary resources (cost share or match), this must be discussed and approved in advance. The department and college should carefully consider whether required matching funds, in-kind contributions, or other cost share are available and allowable. Cost-sharing commitments must be documented and tracked (see Section 7.8).

During proposal development, the PI should also consider space or equipment needs, compliance approvals (for example, IRB or IACUC if applicable), and any other institutional support needed. PIs are encouraged to work with the Office of Academic Research (OAR) and the UEC Sponsored Programs Administration office early in the process for guidance on budget development, Sponsor guidelines, and required internal forms.

3.2 Internal Review and Approval of Proposals

Institutional approval is required before any proposal is submitted to a Sponsor. The following review and approval process must be followed:

Department/Unit Review: The PI’s department chair (or unit director) must review the proposal. The chair/director evaluates: (a) the proposal’s compatibility with the department’s staffing requirements (e.g. can the department accommodate the PI’s time commitments and hiring needs?); (b) compatibility with the department’s academic or programmatic priorities; and (c) the acceptability of any departmental support commitments (such as cost share, use of facilities, or other resources promised). The chair’s endorsement indicates that the department can support the project if funded.
College/Division Review: The college dean (or equivalent divisional administrator) of the PI’s unit must also review the proposal. The dean assesses the proposal’s alignment with college or division interests and objectives and ensures any commitments of college resources are acceptable. The dean’s recommendation signifies that the project is compatible with the college’s current and anticipated activities.
Institutional Approval: Per CSU requirements, written approval from the CSUSB President (or the President’s designee) andfrom the CSUSB’s Chief Financial Officer (or CFO’s designee) is required prior to proposal submission. At CSUSB, this approval is typically obtained through the routing of an internal proposal approval form (or electronic routing system) that captures endorsements from the chair, dean, and relevant administrative offices (e.g. OAR/Sponsored Programs, Academic Affairs, Finance, Technology and Operations). The final institutional sign-off ensures that the CSUSB is willing to commit to the project and comply with the Sponsor’s requirements if an award is made.
Sponsored Programs Office Review: The Office of Academic Research/Sponsored Programs Administration is responsible for a thorough compliance and administrative review of all proposals. This office will verify that all necessary internal approvals have been secured and that the proposal meets CSUSB, Auxiliary, and Sponsor requirements (budget accuracy, allowable costs, compliance approvals, etc.). They also coordinate any required approvals from other units (for example, review by

Risk Management, IRB, IACUC, or Environmental Health & Safety, as applicable, based on the project’s content).

All proposals must be submitted to the Sponsored Programs Office with sufficient lead time to complete these reviews before the Sponsor’s deadline. College deans or other unit heads shall forward proposals to the Sponsored Programs Office in a timely fashion to allow for full review and clearance. The Sponsored Programs Office has the authority to withhold submission if required reviews or approvals are incomplete.

Note: The Office of Academic Research shall ensure that all faculty/staff involved in proposal preparation understand that any resulting award will be made to CSUSB or UEC (the institution), not to an individual. No grant or contract will be accepted in the name of an individual faculty or staff member or solely in the name of a sub-unit of the CSUSB.

3.3 Acceptance of Awards

When a Sponsor decides to fund a proposal, the CSUSB (through OAR/UEC) will usually receive a notice of award or a draft agreement. An award (grant or contract) will not be formally accepted on behalf of CSUSB or UEC without prior written approvals from the appropriate CSUSB and/or Auxiliary officials for all relevant compliance areas. Before signing an acceptance or agreement, the Sponsored Program Administrator must ensure that the following areas have been reviewed and approved (as applicable to the specific award):

Academic/Programmatic: The appropriate academic administrators (dean or AVP) confirm that the scope of work and project commitments are acceptable and that the CSUSB can meet the programmatic requirements of the award.
Fiscal: The CSUSB’s and Auxiliary’s financial officers (e.g. CFO or UEC CFO) review the budget and financial terms. They ensure that matching fund commitments are in place (if required), that indirect costs are applied appropriately, and that the financial aspects comply with CSUSB/Auxiliary policies and Uniform Guidance.
Health and Safety: If the project involves hazardous materials, laboratory safety concerns, fieldwork in potentially dangerous settings, or other health and safety issues, the CSUSB’s Environmental Health & Safety (EH&S) office must approve necessary plans to mitigate risks. Any required safety protocols or training must be agreed upon before acceptance.
Human Subjects Research: If human subjects are involved, the Institutional Review Board (IRB) approval or exemption must be obtained. The award will not be accepted until the IRB (operating under the CSUSB’s Federalwide Assurance) has approved the research protocol or determined it is exempt, and all conditions for human subjects protection are met (see Section 6.2).
Animal Subjects Research: If the project involves live vertebrate animals, the Institutional Animal Care and Use Committee (IACUC) must review and approve the protocol. The CSUSB must ensure that
Space and Facilities: If the project requires additional space, renovations, or special facilities (laboratories, field stations, etc.), the appropriate campus authority must confirm that such space is available and allocated to the project. Facility use agreements or renovations must be planned and approved in advance of acceptance.
Major Equipment/Technical Resources: If the award includes purchase of major equipment or the use of significant university technical resources (e.g. high-performance computing, specialized instrumentation), the CSUSB must verify it can accommodate installation, maintenance, and future costs associated with the equipment. Plans for equipment ownership and location should be in place.
Risk Management: The CSUSB’s Risk Management office must review any unusual liabilities or insurance requirements in the award. If the project involves activities that could expose the CSUSB/Auxiliary to legal or financial risk (such as international travel, youth programs, etc.), appropriate risk mitigation (insurance, waivers, etc.) must be arranged before acceptance. The Auxiliary will ensure it can meet any insurance obligations specified by the Sponsor or required by CSU policy.

housing, care, and use of animals comply with federal regulations and guidelines (see Section 6.3) before work can begin.

Only after all applicable approvals are obtained will the authorized institutional official (such as the Associate Provost for Research or the UEC Executive Director) sign the award agreement or send formal acceptance to the Sponsor. If an award arrives with terms that are problematic or inconsistent with the proposal (for example, reduced funding or altered scope), the Sponsored Programs Office will negotiate with the Sponsor and involve the PI and appropriate administrators to resolve issues before acceptance.

3.4 Amendments to Awards

During the life of a sponsored program, any substantive amendment or modification to the grant or contract must also receive institutional review and approval. Substantive amendments include significant changes such as a major budget revision, a change in the scope of work or key objectives, extending the period of performance, change of the Principal Investigator or other key personnel, or major alterations in project deliverables or terms.

All such amendments or contract modifications must be reviewed by the Sponsored Program Administrator (UEC or CSUSB office handling the award) and approved by the appropriate academic/administrative authorities:

For budget changes or scope changes, the PI should first discuss with their department and dean, then route the amendment through the OAR/Sponsored Programs Office for review.
The Sponsored Programs Administrator’s authorized official must sign any formal amendment on behalf of CSUSB or UEC. This will only be done after confirming the amendment is acceptable and all necessary internal approvals (similar to those in Section 3.3) are in place. For example, adding new human subject research aims may require additional IRB review before the amendment is accepted.
If the amendment involves a change in key personnel or PI (see Section 4.2 on PI Continuity), the procedures for approval of a new PI and notifying the Sponsor must be followed.

In summary, no major change to an awarded project may be made unilaterally by the PI. The same level of institutional oversight used for the original proposal and award acceptance must be applied to amendments to ensure continued compliance and fulfillment of institutional obligations.

4. Post-Award Administration and Responsibilities

Once a grant or contract is awarded and accepted, responsibility for managing the project is shared between the Principal Investigator and the designated Sponsored Program Administrator (CSUSB or UEC), with oversight from relevant academic administrators. This section delineates the roles and responsibilities of key parties in administering sponsored programs.

4.1 Designation of Sponsored Program Administrator

For each sponsored award, it must be clearly designated whether CSUSB (the University) or UEC (the Auxiliary) will serve as the Sponsored Program Administrator. This designation is typically made prior to or at the time of award acceptance (see Section 3.3). The chosen Administrator (CSUSB or UEC) becomes the official recipient entity responsible for day-to-day award management.

The Sponsored Program Administrator is legally and financially accountable to the Sponsor for the use of funds and for ensuring the project is carried out in compliance with the terms of the award. This means that the Administrator is responsible for all official communications with the Sponsor regarding fiscal matters, audits, and contractual obligations.
The Sponsored Program Administrator (whether CSUSB or UEC) must manage the project in accordance with CSU Trustees and Chancellor’s Office policies, applicable federal and state laws (including Uniform Guidance for federal awards), and all relevant CSUSB and Auxiliary policies. UEC, when administering an award, acts as an agent of the CSUSB and must adhere to the same compliance standards.

At CSUSB, University Enterprises Corporation (UEC) is the primary Auxiliary responsible for administering most grants and contracts on behalf of the CSUSB. UEC, as an Auxillary organization, operates under a formal agreement with CSUSB (see Section 4.5) to administer sponsored programs. In cases where the CSUSB (through a specific department or office) is designated to administer an award directly, the same policies and procedures in this document apply to that CSUSB unit.

4.2 Principal Investigator (PI)

The Principal Investigator (or Project Director) is the individual with primary intellectual and managerial responsibility for the sponsored project. The PI is ultimately responsible for achieving the project’s objectives and for complying with the financial and administrative requirements of the award. Key considerations regarding PIs include eligibility, continuity, and specific responsibilities:

Eligibility to Serve as PI: Ordinarily, a PI or Project Director must be a full-time employee of CSUSB or UEC.

Specifically:

A full-time, permanent CSUSB faculty or staff member or
A full-time Auxiliary employee

may serve as a Principal Investigator. Any exception (for example, a part-time employee or a non-employee serving as PI) requires prior approval by the appropriate CSUSB administrator (such as the college dean and/or Provost) and the Associate Provost for Research. This ensures that the individual has a sufficient employment relationship and commitment to the CSUSB and/or Auxiliary to oversee the project responsibly.

Change in PI or PI Incapacity: If a PI resigns, retires, or becomes unable to continue leading the project (due to incapacitation or any reason) during the award period, the following steps must be taken:

The Sponsored Program Administrator (UEC/CSUSB office) and the college dean (or equivalent administrator) will promptly confer to determine an appropriate course of action. The Sponsor will be notified as required by the award terms.
CSUSB will identify an appropriate replacement PI (for example, another faculty or staff member with suitable expertise) in consultation with the Sponsor. The Sponsor usually must approve any change in PI.
If a PI is failing or refusing to adequately perform their project duties (e.g. not carrying out the project work, not complying with requirements), the Sponsored Program Administrator, the Associate Provost for Research, and the college dean will investigate and address the performance issues. If necessary, UEC (as the employer of record for the project – see Section 4.3) may suspend or remove the individual from the project. The institution will then appoint a new PI to ensure the project’s successful continuation or take steps to terminate the project if continuation is not feasible. Any such action will involve coordination with the Sponsor and must comply with CSUSB and/or Auxiliary personnel policies and any applicable collective bargaining agreements.

Principal Investigator Responsibilities: The PI has day-to-day leadership of the project and must ensure that both the programmatic and administrative requirements of the award are met. Specific responsibilities of the PI include:

Programmatic Leadership: Ensuring that the project’s stated aims, scope of work, and deliverables are accomplished in a timely manner. The PI should manage the research or program team, project timeline, and tasks to meet all milestones and outcomes committed to the Sponsor.
Financial Oversight of Project Funds: Authorizing all expenditures on the project account(s) and exercising diligent control over project spending. The PI must use project funds only for budgeted and allowable costs and prevent unauthorized or unallowable expenditures. The PI should maintain up-to-date knowledge of the project’s financial status (expenditures and remaining balance) in collaboration with the Sponsored Programs Administrator’s accounting staff.
Record-Keeping: Maintaining current and accurate records of all financial obligations (encumbrances) and expenditures related to the project. The PI should be able to identify how funds have been allocated and spent, to facilitate reporting and ensure no overspending occurs.
Reporting to Administrator: Providing timely information and reports on project financial activity to the Sponsored Programs Administration office (CSUSB or UEC). For example, if the project requires periodic financial reports or projections, the PI must work with that office to supply any needed programmatic justifications or updates.
Review of Financial Reports: Regularly reviewing the financial reports and statements prepared by the Sponsored Programs Administrator to verify that charges are correct. The PI should promptly communicate any discrepancies or errors to the Sponsored Programs Administration office for correction. This includes monitoring payroll charges, indirect cost charges, and purchase transactions for accuracy.
Project Staff Management: Providing proper supervision and direction to all employees and students working on the project. The PI is responsible for hiring (in conjunction with UEC/CSUSB HR as needed), training, and supervising project personnel, and ensuring their work is aligned with project needs. Personnel issues (performance, time reporting, adherence to policies) should be managed proactively by the PI with support from HR as necessary.
Compliance with Schedule: Adhering to the project schedule and meeting deadlines. This includes timely completion of tasks, submission of progress reports or technical reports to the Sponsor as required and overall ensuring that the project does not unduly delay or request extensions without cause. If timeline adjustments are needed, the PI should coordinate requests for no-cost extensions or other timeline changes through the Sponsored Programs Administrator and obtain Sponsor approval in advance.
Adherence to Sponsor and CSUSB Policies: Ensuring that all project activities are carried out in compliance with applicable sponsor terms, CSUSB/Auxiliary policies, and any regulatory requirements. This could include, but is not limited to, upholding protocols approved by IRB or IACUC, following procurement rules for purchases (see Section 7.3), complying with effort reporting requirements (Section 7.5), and enforcing conflict of interest rules among the project team (Section 5.2).

The PI’s performance of these responsibilities is critical. Failure of a PI to fulfill these duties could result in administrative actions, including removal from the project as described above, and potential disciplinary measures under CSUSB and/or Auxiliary policies (see Section 5.1 on Misconduct).

4.3 Sponsored Programs Administrator (CSUSB or UEC)

The Sponsored Programs Administrator refers to the entity (and its administrative office) that is managing the project on behalf of the CSUSB — typically UEC for most grants, or occasionally a CSUSB department for certain awards. This Administrator carries the institutional responsibility for financial and contractual management of the award. The Sponsored Programs Administrator is legally and financially responsible for the award’s proper administration and must ensure compliance with all applicable policies and regulations. Key responsibilities of the Sponsored Programs Administrator include:

Award Management Liaison: Acting as the primary liaison between the CSUSB and/or UEC and the Sponsor for administrative matters. The Sponsored Programs office communicates with the Sponsor’s grant or contract officers to negotiate terms, request modifications, and ensure the project remains fully funded and can proceed without interruptions. They also serve as a resource to the PI for interpreting sponsor rules or resolving issues.
Policy Guidance and Compliance Assurance: Informing PIs and project staff of all pertinent policies, procedures, and regulations that govern the award. This includes CSU and CSUSB policies, UEC policies, and the specific terms of the individual contract or grant. The Sponsored Programs Administrator must ensure that the project team is aware of and follows these rules. They monitor compliance and may conduct internal compliance checks throughout the project.
Budget Implementation and Contract Interpretation: Assisting the PI with implementing the approved budget. The Sponsored Programs office will set up the project account, post the budget, and guide the PI in allowable cost categories. They also interpret any contractual terms or restrictions for the PI (e.g., rebudgeting rules, prior approval requirements from the Sponsor) and provide follow-up administrative support to resolve any questions or discrepancies that arise in the course of the project.
Financial Transaction Processing: Overseeing all financial transactions on the award. The Sponsored Programs Admin approves expenditures such as requisitions, purchase orders, invoices, payroll, travel reimbursements, and budget transfers, verifying that each transaction complies with the grant/contract and policies and CSUSB processes those financial transactions. Notably, the UEC HR and Payroll functions are handled by the Auxiliary as the employer for project personnel (see Section 4.3 on employment). The Sponsored Programs Admin ensures timely payment of project expenses and that no spending occurs outside the authorized period or budget.
Human Resources Management: Providing human resources and payroll support for the project. UEC (when the Administrator) serves as the employer of record for all grant and contract employees hired specifically for the project. They handle recruitment (in coordination with the PI), hiring, time sheets, payroll processing, and adherence to labor laws and HR policies. They also coordinate any necessary employment actions (evaluations, investigations, discipline, terminations) in consultation with the PI and in accordance with Auxiliary HR policies or CSUSB policies if applicable
Procurement and Purchasing Support: Assisting the PI in obtaining equipment, supplies, and services needed for the project. The Sponsored Programs Admin offers guidance on procurement policies (Section 7.3) and can help solicit bids or quotes, select vendors, and ensure that purchases are made following required competitive or sole-source procedures. They maintain documentation for all purchases to meet audit standards.
Property and Equipment Management: Maintaining proper inventory records for any equipment purchased with project funds. The Sponsored Programs Admin will tag equipment as required, keep an inventory log, and ensure equipment is used and disposed of in accordance with federal regulations and CSUSB and UEC property and equipment policies. They also assist in any necessary reports of equipment to Sponsors and handle disposition of equipment at project end (e.g., title transfer or retention per the award terms).
Financial Monitoring and Controls: Continuously monitoring project account expenditures and encumbrances. The Sponsored Programs Admin provides regular financial reports to the PI and assists in tracking the budget vs. actual expenses. They help the PI maintain budgetary control and will alert the PI (and relevant administrators) if there are any concerns such as overspending in a budget category or approaching budget limits.
Fiscal Reporting to Sponsors: Preparing and submitting all required financial reports and invoices to the Sponsor, in accordance with the award schedule. This includes interim financial reports (quarterly, annual, etc., as required) and the final financial report at closeout. Reports must be timely and accurate, reflecting all expenditures and any program income or cost share as required. The Sponsored Programs Admin ensures that draws of funds or reimbursement requests are done per the Sponsor’s payment method (advance drawdowns, letters of credit, or invoicing) and that cash management requirements (see Section 7.3) are met.
Monitoring Technical Reports: While the PI is responsible for writing and submitting all technical or programmatic reports to the Sponsor, the Sponsored Programs Admin monitors to ensure that the PI meets these requirements. They may remind the PI of upcoming report due dates and, in some cases, they transmit the reports to the Sponsor or confirm submission. The Admin’s role is to help avoid any lapse in reporting that could jeopardize funding.

In essence, the Sponsored Programs Administrator provides the infrastructure and administrative backbone for the project, allowing the PI to focus on the substantive work. The Administrator must uphold all financial, administrative, and audit standards on behalf of CSUSB and/or UEC, and works closely with the PI to address any issues that arise. The Sponsored Programs Administrator or designee must approve certain transactions, such as any reimbursement or payment directly benefiting the PI (to avoid conflicts of interest in approval of one’s own expenditures). Additionally, prior to issuing personnel action forms (hiring or salary changes), the Admin must certify that the funds are available in the project account for that action.

4.4 College Dean or Divisional Administrator

The College Dean (or equivalent divisional administrator for non-academic units) of the PI’s home unit plays a critical oversight role for sponsored projects within their area. This administrator is responsible for supporting the project’s success from an institutional standpoint and ensuring compliance with CSUSB policies at the academic unit level. Specific responsibilities of the Dean or divisional administrator include:

Ensuring Support Commitments: Verifying that the PI has the necessary institutional support and resources as committed in the proposal/award. For example, if the CSUSB promised certain resources (lab space, cost-sharing funds, personnel) in accepting the award, the Dean must ensure those are provided to the project. The Dean helps resolve any resource issues that might impede the project.
Monitoring Project Progress and Delivery: Overseeing the project’s progress to ensure that the PI is on track to deliver the outcomes, products, or services promised to the Sponsor. The Dean does not manage day-to-day work but should stay informed through periodic updates or reports from the PI. If the project is not meeting its objectives or timelines, the Dean may intervene to facilitate support or corrective actions (in coordination with the PI and Sponsored Programs Admin).
Enforcing CSUSB Policies: Exercising administrative oversight to confirm that all CSUSB policies relevant to sponsored programs are followed within their college/division. This includes policies on research integrity, expenditure of funds, additional employment, compensation, travel, and any others that apply. The Dean should work with the PI and Sponsored Programs Admin to correct any deviations from policy.
Workload and Personnel Management: In cooperation with the PI and Sponsored Programs Admin, the Dean monitors the workload of faculty and staff involved in the project. This includes ensuring that any release time for the PI or other faculty is properly arranged and that the college receives reimbursement for that released time according to policy. The Dean ensures that participating faculty are not over-committed beyond allowed limits (e.g. adhering to time and effort commitments and additional employment rules) and that their department’s teaching or service obligations are adequately covered. Essentially, the Dean helps balance project duties with other CSUSB responsibilities.
Review of PI Expenses: Approving and monitoring certain expenses of the PI, especially direct reimbursements or travel expenses incurred by the PI. The Dean (or designee) should review the PI’s travel requests and reimbursements, and any other reimbursements to the PI, to ensure they comply with CSUSB and sponsor regulations (for example, travel must follow UEC travel policy and any sponsor restrictions). This provides an extra layer of oversight for expenditures that personally benefit the PI.
Review of Reports and Communications: Reviewing financial or progress reports provided by the Sponsored Programs Admin or the PI as needed. The Dean can request copies of Sponsor reports or financial statements for their review. If the Dean spots any discrepancies or issues (for instance, an expense that seems out of place or a delay in report submission), they should inform the Sponsored Programs Administrator and work with the PI to address the issue.

In summary, the Dean or divisional head acts as an advocate and overseer for the project within the academic or administrative unit. They ensure the project’s needs are met by the college and that the project, in turn, is adhering to the commitments and standards of the CSUSB. This shared oversight helps integrate sponsored projects into the CSUSB structure and maintain accountability at all levels.

4.5 Agreement Between CSUSB and the Auxiliary (UEC)

CSUSB and University Enterprises Corporation maintain a formal Operating Agreement that delineates the respective rights and responsibilities of the CSUSB and the Auxiliary in the administration of sponsored programs. This agreement (required by CSU policy) ensures that when UEC manages grants and contracts on behalf of CSUSB, both parties understand their obligations. Key provisions of the agreement include requirements that UEC will:

Indemnification: Indemnify, defend, and hold harmless the CSUSB from any loss, damage, or liability arising from UEC’s administration of sponsored programs. In other words, if any legal or financial claims result from how an award was managed by UEC, the Auxiliary accepts responsibility and protects the CSUSB.
Insurance: Maintain adequate insurance coverage as required by CSU and campus policy. This includes general liability, property, workers’ compensation, and any other insurance mandated by Executive Orders or directives (e.g., CSU Executive Order 1069 on Risk Management and Public Safety, and other CSU insurance requirements). The coverage must be sufficient to cover risks associated with administering grants and contracts (including coverage of activities, personnel, and equipment under sponsored projects).
Compliance with Policies: (Additionally, though not listed above, the agreement typically includes that UEC will administer projects in accordance with all applicable laws and CSU/CSUSB policies.

This CSUSB-Auxiliary operating agreement is reviewed and updated periodically to remain compliant with current laws and CSU requirements. It provides the framework within which UEC conducts day-to-day grant administration while the CSUSB retains ultimate oversight authority.

4.6 Project Implementation Plan

For each awarded grant or contract, the Sponsored Programs Administrator (with support from the Office of Academic Research and the PI) will develop an implementation plan to guide the project’s administrative setup and execution. This plan captures important arrangements that may not be fully detailed in the sponsor’s award document. Elements of the implementation plan include, but are not limited to:

Faculty Release Time Compensation: Documenting the amount of any faculty release time that will be charged to the project and the mechanism for reimbursing the faculty member’s college/department for that released time (including salary and benefit rates). This will be done in accordance with the Policy
Additional Employment Details: If faculty will receive additional pay from the grant (for example, summer salary or an overload assignment), specifying the amount and time period of the additional employment. This must align with the Guidelines on CSUSB-Compensated Faculty Additional Employment and CSU policy (ensuring it does not exceed the allowed extra work limits). The plan should note the approval of such additional pay and how it will be administered through payroll.
Compliance Requirements: Confirming any special compliance requirements (IRB, IACUC, conflict of interest disclosures, export controls, etc.) that need to be addressed and listing the steps and responsible parties to fulfill them.
Budget and Spending Plan: Setting up a spending plan or timeline for major expenditures (e.g., equipment purchases early in the project, hiring timelines for personnel, etc.) especially if the project has any time-sensitive expenditures or complex budget structure.
Reporting Schedule: A calendar of internal and external deadlines: sponsor report due dates, internal progress meetings, and financial report intervals, to ensure everyone is aware of key dates.

and Procedures for Reimbursement of Faculty Release Time to ensure the department receives the appropriate backfill funding for the faculty’s time on the project.

While some of these items may have been initially outlined during proposal preparation, the implementation plan serves as a consolidated reference to manage the project. It is typically reviewed with the PI at a project “kick-off” meeting shortly after the award, to confirm mutual understanding of administrative procedures and to answer any questions as the project begins.

5. Ethical and Administrative Compliance

All participants in sponsored programs must adhere to the highest ethical standards and comply with relevant laws and policies. CSUSB has established specific policies to address research misconduct or violations of other standards and policies, discrimination, harassment, conflicts of interest, inappropriate relationships and nepotism, among other issues. The following subsections summarize these expectations:

5.1 Misconduct in Research and Scholarship

CSUSB is committed to the responsible conduct of research and creative activities. The CSUSB has established detailed policies and procedures for handling allegations of research or project-related misconduct, and such policies and procedures are applicable to individuals and actions subject to the above-titled policy. Misconduct can include, but is not limited to: plagiarism, fabrication or falsification of data or results, financial fraud or misuse of grant funds, and serious deviations from accepted practices in carrying out or reporting research.

Key points include:

Applicability: These misconduct procedures apply to all employees, students, and individuals involved in sponsored programs at CSUSB or UEC.
CSUSB Discipline: Individuals working on sponsored programs remain subject to the CSUSB’s and Auxiliary’s disciplinary systems as applicable. Unprofessional behavior, conflicts of interest, failure to adequately perform duties, inappropriate relationships, unethical practices or other misconduct in the context of a sponsored project can lead to disciplinary action by the CSUSB (or Auxiliary) in accordance with established employee or student conduct policies, up to and including termination or academic dismissal.
Reporting Obligation: All members of the CSUSB community are required to report observed, suspected, or apparent misconduct in connection with sponsored programs. This includes reporting any suspicions of data falsification, financial irregularities, violation of research protocols (such as IRB/IACUC violations), or other unethical behavior. Reports should be made to the Associate Provost for Research (or through other channels outlined in the research misconduct policy, e.g., a designated Research Integrity Officer).
Investigation: The CSUSB will promptly and fairly investigate any allegations of research misconduct following its established procedures (which are designed to comply with federal regulations for research misconduct, such as those of the U.S. Office of Research Integrity if PHS-funded research is involved). During an investigation, confidentiality will be maintained to the extent possible, and the rights of all parties will be respected.
Outcomes: If misconduct is substantiated, the CSUSB will take appropriate action, which may include correction of the research record, notifying sponsors or journals, imposing sanctions on the individual(s) responsible, and other remedies as needed. Sponsors will be informed as required (certain federal sponsors mandate notification at various stages of a misconduct investigation).

All project personnel should conduct their work with honesty and integrity. The CSUSB regularly provides training and resources on responsible conduct of research to prevent misconduct from occurring.

5.2 Conflict of Interest

CSUSB and UEC must ensure that conflicts of interest (COI) do not compromise the objectivity or integrity of sponsored projects. A conflict of interest may arise when an individual’s personal financial interests (or those of their immediate family or non-family member involved in a personal relationship as well as other financial or personal interest) could improperly influence the design, conduct, or reporting of a research or programmatic activity, or influence financial decisions involving the project.

Key requirements are:

COI Policy Compliance: CSUSB has a campus Conflict of Interest policy that complies with federal and state law as well as CSU requirements. In addition, certain sponsors (e.g., the National Science Foundation or Public Health Service agencies like NIH) have specific COI regulations. The CSUSB’s procedures incorporate these requirements where applicable. All sponsored projects must adhere to the strictest applicable COI standards.
Disclosure Forms: All investigators and key personnel on a sponsored project are required to complete and sign conflict of interest disclosure forms as provided by the Sponsored Programs Administrator. Typically, this must be done prior to the submission of the proposal or at the time of award, and annually thereafter, or within 30 days of any new reportable significant financial interest. The disclosure will detail any significant financial interests that could relate to the individual’s institutional responsibilities or the sponsored project.
Review and Management: The CSUSB (or Auxiliary) will review disclosures to determine if any significant financial interests could directly and significantly affect the design, conduct, or reporting of the sponsored project. If a conflict is identified, the CSUSB will impose a management plan or other mitigation measures (such as modifying the research plan, oversight by independent reviewers, or, in some cases, prohibiting certain relationships) to manage or eliminate the conflict. In extreme cases, the individual may be disqualified from participation in the project if the conflict cannot be managed.
Non-Compliance: Any individual who fails or refuses to complete required COI disclosures may not be allowed to participate in the project. This is to protect both the individual and the institution from potential legal and financial consequences. Sponsors may also be notified if an investigator is removed for non-compliance with COI requirements.
Procurement Conflicts: (Note: Conflicts of interest in purchasing/procurement are addressed under Section 7.3, as there are additional rules prohibiting staff from influencing purchasing decisions when they have a financial interest in a vendor.)

All project staff must remain vigilant about potential conflicts and work with the CSUSB’s compliance officers to ensure any potential conflicts are disclosed and managed appropriately. Transparency and adherence to these policies maintain the integrity of CSUSB’s research and sponsored activities.

5.3 Nepotism

All CSUSB sponsored programs are subject to the CSU’s Nepotism Policy and CSUSB’s Policy on Nepotism (FAM 607.6). Nepotism (favoritism based on family or personal relationships) is prohibited in employment and contracting decisions. In the context of sponsored programs:

No employee shall be directly supervised by a close relative (such as spouse, domestic partner, romantic or personal relationship, parent/child, siblings, or analogous in-laws) on a sponsored project. If a project team involves or includes family members or persons in a close personal relationship, a plan must be in place so that one does not have evaluative or decision-making authority over the other’s employment or work assignments.
Hiring, promotion, salary, and assignment decisions for project personnel must be made impartially and based on qualifications and project needs, not personal relationships.

The Dean and Sponsored Programs Administrator will ensure that the hiring and supervision structures on grants/contracts comply with the nepotism policy. Any exceptions or special arrangements must be reviewed and approved per CSU’s Nepotism Policy to avoid conflicts of interest or the appearance of impropriety.

6. Research Compliance and Academic Requirements

Sponsored programs often involve research activities that must comply with specific federal regulations and ethical standards. CSUSB maintains institutional committees and policies to oversee these areas. Principal Investigators are responsible for obtaining and adhering to necessary approvals in the following areas (with support from the relevant compliance offices):

6.1 Conduct of Research

The CSUSB expects all research and scholarly activities to be conducted rigorously and ethically. The College Dean or appropriate administrator (as noted in Section 4.4) is responsible for general oversight of research conduct within their unit. They work with the PI and Sponsored Programs Administrator to ensure the project remains on track to fulfill the grant or contract requirements. This includes verifying that the research is being carried out as proposed and that any issues (technical or administrative) that could impede progress are addressed. In practice, PIs meet this requirement by submitting progress reports to both Sponsors and internally (if requested), and by engaging in regular communication with their Dean/department on research progress. Should significant issues in research conduct arise (e.g., inability to produce promised deliverables), the Dean will collaborate with the PI and Sponsored Programs Admin to develop and implement a resolution plan or, if necessary, re-scope or terminate the project in consultation with the Sponsor.

6.2 Human Subjects Research

CSUSB’s Institutional Review Board (IRB) governs all research involving human subjects to ensure ethical and regulatory compliance (per 45 CFR 46 and other applicable regulations). The CSUSB’s Policy Concerning Research Involving Human Subjects (FAM 845.72) establishes the IRB and its authority. Key points for sponsored projects involving human subjects:

Federal Assurance: CSUSB maintains a Federalwide Assurance (FWA) approved by the Department of Health and Human Services’ Office for Human Research Protections (OHRP). This signifies the CSUSB’s commitment to comply with federal regulations for the protection of human subjects.
IRB Approval: No human subjects research activities (including recruitment, data collection, or analysis of private identifiable data) may begin under a sponsored project until the IRB has reviewed and approved the research protocol (or determined it exempt from IRB review). This applies regardless of funding source (federal or otherwise).
Ongoing Compliance: The PI must comply with all IRB requirements throughout the project, including obtaining informed consent from participants, securing data appropriately, submitting any protocol modifications for prior IRB approval, and reporting any adverse events or unanticipated problems to the IRB immediately. Continuing review (annual or as stipulated by the IRB) must be sought to maintain IRB approval. The Sponsored Programs Admin may check that IRB approvals are in place before releasing funds for human subject research portions of the project.

Training: Investigators and research staff must complete human subjects protection training as required by the IRB before engaging in the research. The IRB chair and the Associate Provost for Research are responsible for ensuring that all researchers have appropriate training (often via CITI Program or equivalent).

In summary, the IRB has oversight of the ethical conduct of human subjects research, and the CSUSB must uphold IRB decisions. The President designates the IRB Chair and the Associate Provost for Research to implement human subjects protections campus-wide. Compliance with IRB requirements is mandatory and a condition of the award when human subjects are involved.

6.3 Animal Subjects Research

CSUSB’s policy on the care and use of animals in research and instruction (FAM 806.43) establishes the Institutional Animal Care and Use Committee (IACUC) and outlines procedures to ensure humane treatment of vertebrate animals. For sponsored projects involving animals:

IACUC Approval: All research or instructional use of live vertebrate animals conducted under CSUSB auspices (including Auxiliary-managed projects) must receive IACUC approval before commencing. This applies to animals used on campus or in field research, by faculty, staff, or students. The IACUC reviews animal use protocols to ensure compliance with federal laws (e.g., the Animal Welfare Act and Public Health Service Policy on Humane Care and Use of Laboratory Animals) and ethical standards.
Animal Care Standards: The CSUSB is committed to following the Guide for the Care and Use of Laboratory Animals and regulations of the U.S. Department of Agriculture. Adequate veterinary care, appropriate housing, and trained personnel are required for all animal work. The IACUC conducts semiannual inspections of animal facilities and reviews of the program.
Training and Safety: Personnel working with research animals must be appropriately trained in animal care, handling, and the specific procedures outlined in the approved protocol. Occupational health and safety programs (such as allergy prevention or zoonotic disease prevention) must be in place for personnel as needed.
Monitoring: The IACUC has the authority to suspend any animal activity that is not in compliance. The CSUSB (through the IACUC and the Associate Provost for Research) ensures that any mandated federal reports (for example, annual reports to OLAW or USDA) are submitted, and that any Sponsor requirements regarding animal subjects (like NIH’s requirements for vertebrate animal sections in proposals or prior approvals) are met.

The CSUSB’s responsibility is to ensure humane and ethical treatment of animals at all times. No aspect of animal research can proceed without adherence to these standards, regardless of funding. The President or designee appoints IACUC members and ensures institutional support for the animal care and use program so that sponsored projects involving animals fully comply with all requirements.

(Note: In addition to IRB and IACUC, other compliance areas may include biosafety (for work with biohazards/recombinant DNA), radiation safety, export controls, etc., depending on the project. While not explicitly detailed in this policy, PIs are expected to obtain any required approvals or training in these areas as part of the award conditions. The Sponsored Programs Office will help direct PIs to the appropriate compliance committees or officers during the proposal and award setup process.)

7. Financial Administration and Accountability

The financial management of grants and contracts must meet both CSUSB standards and the specific requirements of Sponsors (especially the federal Uniform Guidance for federal awards). CSUSB and UEC are responsible for sound fiscal stewardship of all sponsored funds. This section outlines requirements for budgeting, expenditures, fiscal controls, reporting, and other financial aspects of sponsored programs.

7.1 Budgets and Disbursements

Each sponsored award operates under an approved budget that allocates the Sponsor’s funding (and any cost share, if applicable) into specific categories (such as salaries, benefits, equipment, supplies, travel, etc.). Adherence to the budget is crucial:

The Sponsored Programs Administrator is responsible for the final review and certification of the project budget at the time of award setup. This includes ensuring that the budget entered into the accounting system matches the Sponsor-approved budget and any internal allocations (for example, noting how much is reserved for subcontracts or participant support costs).
The Sponsored Programs Administrator will also implement budget change procedures. If the PI needs to rebudget funds between categories, the Administrator will determine whether the change is allowable under sponsor guidelines or if sponsor prior approval is required. They will assist the PI in requesting approval for budget revisions when necessary.
The Principal Investigator is responsible for executing the project within the bounds of the approved budget. The PI should plan project activities so that expenses stay within each budget category as authorized (unless modified with approval). The PI cannot independently reallocate funds in ways that violate the Sponsor’s restrictions (for example, spending equipment funds on travel without approval if the sponsor prohibits that).
No expenditures can be made until an award is fully executed (signed by all parties) and all required approvals are in place. The Sponsored Programs Administrator must verify that the contract or grant agreement is finalized and, if required, that a sponsored project account is established, before
In some cases, a Sponsor may allow pre-award costs or spending before the official start date or before the agreement is signed (common with federal awards up to 90 days prior to start, or in situations where there’s a delay in finalizing a contract). If pre-award spending is anticipated and permitted by the Sponsor, the Sponsored Programs Administrator must have a written policy in place for authorizing pre-award spending. The PI must obtain approval through that process (which often involves guaranteeing another fund source in case the award doesn’t come through). Only then can pre-award expenditures be processed, and they must align with both Sponsor rules and CSUSB/Auxiliary risk considerations.
The Sponsored Programs Administrator ensures that fund disbursements (payments) are made in compliance with all requirements. For example, they will not pay an invoice or reimburse an expense that falls outside the project period or is for an unapproved budget item. Should any questions arise, the Administrator will consult with the PI and possibly the Sponsor before disbursing funds.

allowing charges. In other words, project spending cannot start just on the notice of award alone; formal acceptance and account setup are prerequisites.

In summary, maintaining financial discipline according to the budget prevents cost overruns and audit findings. Both the PI and the Sponsored Programs Administrator must work together to manage funds prudently and make adjustments only through proper channels.

7.2 Financial Controls and Accounting

Sound accounting practices and internal financial controls are essential for managing sponsored funds. The Sponsored Programs Administrator is responsible for establishing and enforcing these controls for each award:

Account Setup: Promptly after an award is accepted, the Sponsored Programs Admin will set up a distinct account (or fund) in the financial system for the project. This account will be structured to track all revenues and expenditures related to the specific Contract/Grant. Separate accounts or sub-accounts may be created for sub-awards, cost sharing, or specific budget segments if needed. The account setup will reflect any sponsor-imposed restrictions (e.g., separate tracking for participant support costs or capital expenditures).
Approval Authority: The Administrator must have clear delegations of authority on file, indicating who can approve various transactions (requisitions, travel, payroll, budget changes) on the project. Typically, the PI has authority to initiate expenditures, but certain actions may require higher-level approval (for instance, the UEC Executive Director approving equipment over a threshold, or the Dean approving PI travel as noted). Procedures will define these approval workflows to prevent unauthorized transactions.
Expense Compliance Review: All expenditures are reviewed by the Sponsored Programs Admin staff to ensure they are allowable, reasonable, and allocable to the project per the contract terms and Uniform Guidance cost principles. They verify the expense occurs within the active period of the award and that funds are available in the appropriate budget category. If an expense is questionable or not clearly
Cash Receipts and Deposits: The Sponsored Programs Administrator manages the receipt of funds from Sponsors. This includes drawing down funds from federal payment systems, invoicing sponsors per schedule, and recording payments. Proper controls (separation of duties, reconciliation processes) are in place to ensure all payments due are received and deposited correctly. Cash management is handled so that federal funds are drawn only as needed to cover immediate expenditures (minimizing time that federal cash is on hand, per 2 CFR 200.305), and any program income generated is accounted for according to sponsor instructions.
Payroll and Effort Certification: For personnel paid from the project, the Admin ensures payroll is correctly charged to the project account and that salaries correspond to approved budget amounts or effort levels. Effort reporting (Section 7.5) is integrated as an internal control to verify that payroll charges are accurate. Typically, after-the-fact effort certifications are required each semester or on a schedule to confirm that salaries paid from the grant reflect actual work performed.
Account Reconciliation: The project’s financial accounts are periodically reconciled. The Sponsored Programs accounting team will compare the account records to source documents and bank statements, and also reconcile Sponsor drawdowns to expenditures for accuracy. Any reconciling items (such as a charge appearing incorrectly) will be investigated and corrected promptly.
Audit Readiness: The Administrator maintains all financial records and supporting documentation in an orderly manner to be prepared for audits. They ensure that for every expense, required documentation (receipts, invoices, approvals) is retained. They also track any cost share contributions in the accounting system for later verification.
Prior Approvals and Notifications: Some financial actions require Sponsor approval (e.g., rebudgeting beyond a certain percentage, no-cost extension, purchasing a item not in budget). The Sponsored Programs Admin will coordinate these requests and get written sponsor approval before proceeding with the action, documenting the approval in the files.
Separation of Duties: The financial management is structured to have checks and balances. For instance, the person who initiates a purchase should not be the person who approves the payment; the person who prepares a financial report is not the same who approves transactions; and so on. This reduces risk of errors or fraud.

permitted, the Administrator will hold or deny the transaction and consult with the PI for justification or alternative funding.

Additionally, CSUSB and UEC will ensure compliance with Uniform Guidance’s financial management standards. The CSUSB and UEC undergo an annual financial audit, and if the federal expenditures meet the threshold, a Single Audit (2 CFR 200 Subpart F) is performed by external auditors. The Sponsored Programs Admin cooperates fully with auditors, provides all requested records, and addresses any audit findings with corrective action. The CSUSB and UEC are committed to resolving any internal or external audit issues and continuously improving financial controls.

In summary, effective financial controls protect the integrity of sponsored funds, ensure compliance with sponsor requirements, and provide accountability such that all expenditures can withstand scrutiny by auditors or sponsor representatives.

7.3 Cash Management

Proper cash management ensures that the flow of funds between CSUSB and/or UEC and Sponsors is handled efficiently and in compliance with federal regulations:

Advances vs. Reimbursement: Sponsors use different payment methods. Federal grants often allow drawdowns (advances) via systems like ASAP or PMS, whereas some contracts require invoicing after expenses are incurred (reimbursement). The Sponsored Programs Admin will follow the payment method specified.
Minimizing Cash on Hand: In accordance with 2 CFR 200.305(b), when CSUSB and/or UEC draws down federal funds in advance, it will time the drawdown so that funds are used for project expenses as soon as possible (generally within 3 business days). Excess federal cash will not be kept on hand. If funds are drawn and not spent timely, they will be returned or offset against subsequent draws as required.
Invoicing: For awards where UEC/CSUSB must send invoices to the Sponsor (monthly or quarterly, etc.), the Sponsored Programs Admin will submit timely, accurate invoices reflecting allowable costs incurred. They will track accounts receivable and follow up on any late payments from sponsors.
Separate Bank Account (if required): If a sponsor or regulation requires keeping advanced funds in an interest-bearing account, the Admin will ensure compliance. Typically, for federal funds, any interest earned above $500 per year is remitted back to the U.S. Treasury as required by Uniform Guidance. In most cases, UEC integrates grant cash in its accounts but calculates interest as needed.
Program Income: If the project generates program income (e.g., fees for services, sale of commodities, registration fees for a conference funded by the award), the PI must inform Sponsored Programs Admin. The Admin will account for program income separately and apply it according to sponsor policy (deducted from the award, added to the project, or used for cost share, per the terms of the award). Financial reports will include program income as required.
Foreign Currency (if applicable): For any international projects, currency exchange issues will be handled such that the value of sponsor funds is preserved and any gains/losses are managed per sponsor rules.
Close monitoring: The Sponsored Programs Admin monitors the burn rate of funds. If a project is spending significantly faster or slower than anticipated, they might alert the PI and possibly the sponsor (especially if required to report deviations). The goal is to avoid large unspent balances or overruns at the end of the project.

By actively managing cash, CSUSB and/or UEC maintains compliance with federal cash management requirements and ensures that the project always has the liquidity needed to operate while also safeguarding sponsor funds from misuse.

7.4 Procurement Standards

All purchasing and contracting activities under sponsored projects must comply with CSUSB/Auxiliary procurement policies and any additional sponsor-imposed requirements. Federal awards are subject to the procurement standards of 2 CFR 200.317-327.

In summary, procurement under grants and contracts will be handled with the same diligence and regulatory compliance as any CSUSB purchase, with added attention to federal requirements for fairness and transparency. PIs should coordinate all significant purchases with the Sponsored Programs Admin to make sure these rules are followed, thus avoiding disallowed costs or other issues.

7.5 Compensation and Effort Reporting

Time and effort reporting is required to ensure that salaries and wages charged to sponsored projects are justified by actual work performed. Both federal regulations (2 CFR 200.430) and CSUSB policy mandate that the distribution of an employee’s time devoted to various activities (including sponsored projects) is documented and certified. Key points include:

Payroll Allocation: Initially, an employee’s salary charged to a grant should be based on an estimated allocation of effort (for example, a faculty member plans to spend 30% of their time on a project during a semester, so 30% of their salary is charged to the grant). These allocations must align with the project budget and the individual’s appointment (and not exceed allowed limits for additional employment as discussed in Section 4.2 and 4.3).
Effort Certification: After-the-fact, the CSUSB/Auxiliary uses an Effort Reporting system to confirm that the payroll charges are consistent with the actual effort expended on the project. Typically, each employee (or their supervisor/PI) will certify a statement (often every semester or quarterly) indicating that, to the best of their knowledge, the proportion of time the employee spent on each sponsored project (and other activities like teaching or administration) is accurately reflected by the salary charged. At
Certification Process: The PI will review and certify effort for themselves and usually for any staff or students working on their projects (unless those individuals certify their own, per policy). The certification attests that “the work (or effort) that I or my employee performed on this project during the period is at least equivalent to the salary charged.” If an individual was paid 50% from a grant and 50% from other sources, they must have devoted approximately half their time to the grant’s activities in that period.
Adjustments: If the certified effort percentages differ from the original payroll distribution (for example, someone spent more time on the grant than planned or less), the payroll charges must be adjusted accordingly. The Sponsored Programs Admin will process retroactive payroll cost transfers to align salary charges with actual effort. Note that large or late adjustments are frowned upon and could be audit triggers, so the goal is to have reasonably accurate charges throughout and minimal adjustments.
Record Retention: Certified effort reports are kept on file as auditable documents. They provide auditors evidence that the institution has internal controls to ensure salary costs are appropriate. Lack of proper effort certification can lead to disallowed salary costs in an audit.
Concurrent Effort (Multiple Projects): If an individual works on multiple awards or activities, they must certify effort across all in total to 100% of their workload. This ensures they are not over-committed beyond 1.0 FTE (or beyond allowed overload). The effort reporting system accounts for all funding sources so that the sum of effort equals the individual’s total institutional responsibilities.
Idle time or Reduced Effort: If a PI significantly reduces their effort on a project (e.g., a reduction of 25% or more of what was budgeted for the PI’s time), many federal sponsors require prior approval. The PI must inform the Sponsored Programs Admin of any plans to reduce their time so sponsor approval can be obtained if required.
Compliance: Effort reporting is a critical compliance area. CSUSB and/or UEC will provide training and reminders to faculty and staff to complete certifications on time. Failure to comply with effort reporting can result in financial penalties, the need to refund salary costs to the sponsor, or loss of future funding. Therefore, the CSUSB treats timely effort certification as a high priority.

CSUSB and/or UEC, effort reports may be required on a semester basis for faculty and every six months or monthly for staff, depending on the system in place.

In summary, time and effort reporting is the mechanism by which the CSUSB and/or UEC provides assurance that federal funds (and other sponsor funds) have only paid for the actual time that employees devoted to those projects. It is both a sound management practice and a required compliance activity. The PI and each staff member should treat effort certification as an integral part of the project’s administration.

7.6 Fiscal Reporting

Financial reporting to Sponsors is an essential obligation of the Sponsored Programs Administrator:

The Sponsored Programs Admin will prepare all required interim and final financial reports for the sponsor. These reports detail the expenditures of the award funds (and sometimes also include reporting
Timeliness: Financial reports must be submitted by the deadlines stated in the award agreement (e.g., quarterly reports due 30 days after each quarter, final financial report due 90 days after project end, etc. – note that Uniform Guidance now allows 120 days for final reporting if the agency permits). The Administrator has systems in place to track these deadlines to avoid late reporting, which could delay payment or affect future funding.
Accuracy: All reports are checked against the official accounting records. Typically, the final financial report will reflect expenditures as reconciled in the accounting system at closeout. The PI might be consulted to ensure all appropriate charges have posted and any final invoices or charges are accounted for. Once submitted, the financial report effectively “closes” the award financially, and any later adjustments are difficult or impossible, so care is taken to get it right.
Final Invoice vs. Final Report: In some cases, a final invoice serves as the final financial report (for example, in cost-reimbursement contracts). In others, a separate standardized form (such as the federal SF-425) is used. The Sponsored Programs Admin handles whichever format is required.
Unexpended Funds: If there are unspent funds at the end of a cost-reimbursement grant, those funds typically lapse back to the sponsor (the final report will show them as unobligated balance). In fixed-price agreements, unspent funds might be retained by the CSUSB/Aux if allowed, but often sponsors prefer spending to match the planned budget. The Admin will coordinate any necessary return of funds or carryover requests if the project is under budget.
Closeout Coordination: The financial report is part of award closeout. The Admin will also ensure that all sponsor-required closeout documents are submitted, which may include not just the financial report but also property/inventory reports, patent/invention statements, and subrecipient final reports. The PI is responsible for the final technical report to the sponsor, but the Admin may remind or assist the PI in confirming its submission since many agencies link final payment to the receipt of all reports.

of any cost sharing, program income, or interest earned, as applicable). They are usually on a cash or accrual basis as specified by the sponsor.

By fulfilling all financial reporting requirements, CSUSB and/or UEC demonstrates accountability for the funds provided by the Sponsor and helps maintain the CSUSB and/or UEC’s reputation as a responsible steward of sponsored awards.

7.7 Indirect Costs (F&A) Recovery

Indirect costs (also known as Facilities & Administrative costs, or F&A) represent the real expenses of university operations that support sponsored activities but cannot be directly attributed to a single project (examples include utilities, administrative services, building use, etc.). CSUSB and UEC have negotiated F&A rate agreements with the federal government that determine the percentage of indirect costs that can be applied to sponsored projects.

Policy on indirect cost recovery:

CSUSB and UEC shall seek to recover the maximum allowable indirect costs on all sponsored projects, in accordance with the approved federal F&A rate or the Sponsor’s published policy. This ensures that the CSUSB’s infrastructure costs are supported and not inadvertently subsidized by state funds or other sources.
All proposals must include the appropriate F&A rate (applied to the appropriate base) unless a sponsor has a written restriction on indirect costs (for example, many foundations cap or prohibit indirect costs – such limitations must be documented). Any waiver or reduction of the normal indirect cost rate requires approval through the CSUSB’s waiver process (usually approval by the Provost or CFO), because it represents a cost share by the CSUSB.
The Sponsored Programs Admin will calculate indirect cost charges periodically (monthly, for example) by applying the rate to the allowable base expenditures (such as modified total direct costs) and will charge the project account accordingly. These recovered funds are allocated according to CSUSB and/or UEC policy – typically shared among the UEC, CSUSB, and generally returned in part to colleges or departments to incentivize research (as per any indirect cost distribution formula in place).
The policy applies to all sponsored programs whether they are grants, contracts, cooperative agreements, etc. There may be some activities (instructional grants, training grants) where a different F&A rate (e.g., off-campus rate or a lower rate for training) is applicable based on the negotiated agreement – the correct rate type must be used as appropriate.
When an award has restrictions (for instance, an NIH training grant that has an 8% indirect cap, or a State of California grant that limits indirect costs), the restriction is honored. The proposal budget should clearly reflect those limitations so that recovery expectations are set accordingly.

By recovering indirect costs, the CSUSB can sustain the administrative and facility environment needed to support research and sponsored activities. All project budgeting and accounting should recognize indirect cost recovery as an integral part of sponsored program finance, as required by CSU and campus policy.

7.8 Cost Sharing (Matching)

Cost sharing refers to that portion of the project costs not borne by the Sponsor but by the CSUSB or a third party. It can be in the form of cash contributions, faculty effort, or in-kind contributions (such as donated services or equipment use). CSUSB’s approach to cost sharing is as follows:

Approval of Cost Share Commitments: Cost sharing should be included in proposals only when required by the Sponsor or when necessary to make a proposal competitive, and it must be approved during the proposal routing process. Voluntary (not sponsor-mandated) cost sharing is generally discouraged because it imposes additional burden on the CSUSB and becomes an auditable commitment.
Documentation of Cost Sharing: When cost sharing is committed in an award, the Sponsored Programs Admin, in conjunction with the PI, must track and document all cost share contributions. This includes keeping records of expenses paid by the CSUSB and/or Auxiliary that count toward the match (e.g., salaries paid from CSUSB funds for time devoted to the project, or lab supplies furnished by the CSUSB) as well as third-party contributions (like a collaborator’s effort funded by their own institution).
Accounting for Cost Share: If cost sharing is substantial, a separate account may be established to accumulate those expenses for clarity. All cost-shared expenditures should be verifiable in the accounting system or through signed third-party statements. They must meet the same allowability criteria as direct sponsor-funded costs (e.g., cannot include unallowable expenses).
Consistency with Cost Principles: Cost shared expenses must be allowable, allocable, and reasonable under Uniform Guidance if it’s a federal project. For example, if rent is unallowable as a direct cost to the grant, the CSUSB cannot count free rent of a space as cost share. Also, the same cost can’t be used as cost share on more than one project or counted towards multiple obligations (no “double counting”).
Reporting Cost Share: The Sponsored Programs Admin will report cost sharing to the Sponsor as required (some sponsors require annual or final reports of how cost sharing was met). These reports will detail the categories and amounts of cost share contributed.
Fulfillment: It is critical that the CSUSB meets the exact cost share commitment made. If the commitment is $50,000 of matching funds, the CSUSB must provide at least $50,000 in eligible costs by project end. If under-delivered, the sponsor might reduce their funding proportionally. Conversely, providing more than committed might not be necessary or even desirable (some sponsors don’t give “credit” for over-match and it could unnecessarily burden the CSUSB).
Uniform Guidance Compliance: For federal awards, cost sharing is subject to 2 CFR 200.306 and must be recorded and accounted for “as required by the Federal awarding agency.” The Uniform Guidance also notes that voluntary cost sharing is not expected (and cannot be used as a factor in merit review of proposals, except in specified circumstances). CSUSB follows these principles, focusing on mandatory cost sharing or that which is specifically documented in the project scope.

In summary, while cost sharing may sometimes be essential (especially for certain grants that require institutional support), it must be handled with the same level of oversight as the sponsor’s funds. The Sponsored Programs Administrator and PI ensure that any promised CSUSB contributions are provided and properly tracked to satisfy sponsor expectations and audit requirements.

7.9 Subawards and Subrecipient Monitoring

Many sponsored projects involve collaborations where CSUSB and/or UEC issues a subaward to another institution or organization to carry out a portion of the work (as opposed to procurement of goods/services, which is handled under Section 7.3). When CSUSB and/or UEC is the prime recipient and passes funds to a subrecipient, the Uniform Guidance (2 CFR 200.331 – 200.333) requires oversight of subrecipients. Key requirements:

Subaward Agreements: The Sponsored Programs Admin will prepare a formal subaward agreement with each subrecipient, which includes all required flow-down provisions from the prime award (such as federal requirements, terms and conditions, and any special requirements the sponsor imposes). The agreement will specify the subrecipient’s scope of work, budget, period of performance, reporting obligations, and the basis for payment (e.g., cost-reimbursement or fixed amount). It also includes terms for modifications or termination if needed.
Risk Assessment: Before issuing a subaward, CSUSB and/or UEC will assess the subrecipient’s risk of non-compliance (e.g., considering factors like their prior experience with similar awards, results of previous audits, etc.). Depending on the risk level, the CSUSB and/or UEC may impose specific monitoring measures (like more frequent reporting or on-site visits) to ensure proper stewardship of funds.
Monitoring Activities: The PI and Sponsored Programs Admin share responsibility for monitoring subrecipients. The PI should stay in regular contact with subrecipient investigators to review progress and ensure the work is being accomplished as planned. The Sponsored Programs Admin monitors financial and compliance aspects, which include:
- Reviewing subrecipient invoices to ensure charges appear reasonable and within the subaward’s scope. The PI often approves each invoice indicating the subrecipient’s work is satisfactory and deliverables (if any due by that invoice) have been received.
- Making sure subrecipients submit any required technical reports or deliverables on schedule.
- Tracking that the subrecipient is meeting any cost-sharing commitments they have (if the subrecipient promised cost share, it must be documented).
- If necessary, performing on-site visits or desk reviews of subrecipient documentation. This might be done if red flags arise or as part of a risk-mitigation plan for a high-risk subrecipient.
- Taking action if subrecipient performance or compliance is inadequate (this could range from providing technical assistance to, in worst cases, suspending or terminating the subaward).
Subrecipient Audits: For subrecipients that are federal grant recipients, the Uniform Guidance requires that any subrecipient expending ≥$750,000 in federal funds in a year must have a Single Audit. CSUSB and/or UEC will obtain the subrecipient’s audit results or certifications each year. The Sponsored Programs Admin will review any findings related to the subaward; if there are findings, CSUSB and/or UEC will issue a management decision on how the findings are being addressed, and may impose conditions or
Record Keeping: CSUSB and/or UEC keeps on file all subaward agreements, modifications, invoices, and relevant correspondence. This documentation demonstrates that we have exercised proper oversight.
Timely Closeout: Subrecipients must submit final invoices and final reports in a timeframe that allows CSUSB and/or UEC to meet our own sponsor deadlines. The subaward agreement will state that (for example, requiring final invoice within 45 days of subaward end). The Sponsored Programs Admin will hold the subrecipient to those dates and complete a closeout review (ensuring all obligations were met) before releasing final payment.

require remedies by the subrecipient. If a subrecipient is not subject to Single Audit (e.g., a for-profit entity or foreign entity), CSUSB and/or UEC may require other assurances or audits to ensure compliance.

Through diligent subrecipient monitoring, CSUSB ensures that collaborators carry out their portion of the work in compliance with award terms and that the overall project remains in good standing. Remember, the prime awardee (CSUSB and/or UEC) is ultimately responsible to the Sponsor for any issues with subrecipients, so proactive monitoring is both good practice and required by federal rules.

8. Sponsored Program Work Products and Records

Sponsored programs often generate tangible or intangible results (work product) and always involves record-keeping. The ownership and use rights of project results and the proper retention of project records are important considerations:

8.1 Intellectual Property and Work Products

Results and outcomes of sponsored programs can include publications, data sets, inventions, software, reports, curriculum materials, and other intellectual property. CSUSB’s intellectual property policies (e.g., FAM 500.8 on Patents and Copyrights) and CSU systemwide policies govern ownership of such work. By default:

CSUSB Ownership: In general, works created in the performance of a sponsored program are owned by the CSUSB and/or Auxiliary, unless specified otherwise in the sponsorship agreement. For example, data collected under a grant is considered part of the sponsored program work product that the CSUSB and/or Auxiliary holds on behalf of the project.
Sponsor or Third-Party Rights: Some contracts or grants include terms that give the Sponsor certain rights to the work product (such as a license to use data or an agreement that a report will be the property of the Sponsor). As long as these terms do not conflict with law or CSU policy, they are acceptable, but they must be reviewed and approved during contract negotiation. If a contract or grant intends to assign ownership of an invention or copyrightable work to the Sponsor or another party, it must be agreed to by the CSUSB and/or UEC in the award. The CSUSB and/or UEC may negotiate retaining a license for its own use, or other modifications, if needed to protect academic freedoms or future research.
CSUSB License Clause: If an agreement grants the Sponsor or an outside entity ownership of any work product or data, CSUSB will ensure that the agreement reserves for the CSUSB a royalty-free, nonexclusive license to use those work products and data for education and research purposes. For example, if a Sponsor is given ownership of software developed, the CSUSB will retain the right to use that software internally for research/education. Similarly, any research records (even if delivered to sponsor) should be accessible to the CSUSB for academic purposes.
Scholarly Works Exception: Traditional scholarly works (like journal articles, scholarly papers, or textbooks) that are authored by faculty in the course of research, even sponsored research, are usually not claimed by the CSUSB as “work for hire” – they remain the intellectual property of the creators, subject to academic publication practices. The sponsored program terms typically acknowledge the right of faculty to publish results (after any sponsor-required review for confidential info or patentable inventions).
Inventions (Patents): All faculty, staff, students, and other project personnel must promptly disclose any potentially patentable invention arising from sponsored or university-supported work to CSUSB’s Office of Academic Research or other designated technology transfer authority. The determination of inventorship, ownership, assignment, management, and licensing rights shall be made in accordance with applicable law, CSU and CSUSB intellectual property policy, sponsor terms and conditions, and any applicable assignment, subcontract, collaboration, or inter-institutional agreement. The filing of a provisional or other patent application by the University does not, by itself, determine ownership. In cases involving external collaborators or co-inventors, CSUSB’s rights shall extend only to those interests properly assigned or otherwise conveyed to the University or its authorized auxiliary/entity, unless a written agreement provides otherwise. Any sponsor option, license, government-rights provision, or other federally required invention obligation, including those arising under Bayh-Dole, shall be administered in accordance with the governing award or agreement.
Acknowledgment and Usage: Regardless of ownership, the CSUSB always retains the right to access data and work products for purposes of complying with legal or regulatory requirements, such as responding to audits or inquiries, or reporting to the sponsor. Moreover, unless restricted, the CSUSB can use information from the project to enhance teaching, further research, and publicize the work (with proper sponsor acknowledgment).

• Methodological and Derivative Research Work Product: To the extent created in the performance of a sponsored program, coding schemes, codebooks, analytic frameworks, derived or reconstructed datasets, statistical syntax, scripts, models, taxonomies, protocols, instruments, and other derivative methodological tools or approaches constitute Sponsored Program Work Product unless otherwise governed by applicable law, sponsor terms, or CSU/CSUSB intellectual property policy. The ownership, attribution, use, disclosure, transfer, and protection of such work product shall be determined in accordance with applicable law, sponsor terms and conditions, and any applicable assignment, subcontract, collaboration, data use, or inter-institutional agreement. CSUSB and/or its authorized auxiliary/entity shall take reasonable steps to acknowledge and protect the intellectually creative contributions embodied in such work product.

• Federal Public Access Compliance: For federally funded sponsored programs, peer-reviewed publications, author accepted manuscripts, and scientific data subject to applicable public access or data-sharing requirements shall be managed, deposited, and made available in accordance with the governing award, applicable federal law and regulation, and the applicable federal agency’s public access plan, repository requirements, and award terms. No copyright transfer agreement, publication agreement, or other third-party publishing arrangement shall be accepted or interpreted in a manner that conflicts with the Recipient’s or CSUSB/UEC’s pre-existing obligations under the federal award, including any Federal agency royalty-free, nonexclusive, irrevocable license or other government-use rights reserved by law or award terms. Compliance with such federal public access requirements shall be coordinated through the Office of Academic Research and shall not be construed to require payment of a publisher or open-access fee solely to permit deposit or public access where the applicable agency policy allows compliance without such payment.

In practice, the Office of Academic Research’s Office of Sponsored Programs Administration and will coordinate with the CSUSB’s intellectual property officers to ensure that any contract terms about work product are acceptable. CSUSB’s goal is to both honor sponsor requirements and preserve the CSUSB’s mission-related rights to use knowledge generated from sponsored work.

8.2 Record Retention and Access

Proper retention of sponsored program records is critical for audits, future reference, and legal compliance. CSUSB and UEC will follow all applicable record retention requirements:

Retention Period: Sponsored program records must be retained for at least the minimum period required by the Sponsor or by law. For federal awards, Uniform Guidance (2 CFR 200.334) generally requires that financial and programmatic records be kept for three years from the date of submission of the final expenditure report (or from the date of final payment, whichever is later). However, some records may need longer retention:
- If any litigation, claim, or audit is started before the expiration of the three-year period, records must be kept until all issues are resolved and final action taken.
- Certain sponsor or program regulations may specify a longer period (e.g., records for equipment may need to be kept for three years after final disposition of the equipment).
- For projects involving human subjects, IRB records might be kept for at least three years after study completion (or longer if required by FDA or other regulations).
- The CSUSB may have its own policy to retain grant files for a longer period (for instance, some choose five or seven years retention). UEC/CSUSB will establish a retention schedule and follow whichever is longest of CSU policy, campus policy, or sponsor requirement.
Stored Records: Records include both physical documents and electronic records. They should be stored securely and in a manner that protects them from damage or loss. Financial records (ledgers, receipts, invoices), HR records (timecards, effort reports), technical reports, correspondence, and approval documents are all part of the file. The Sponsored Programs Administration typically keeps the official award file. PIs should also keep copies of important project documents (especially research data and lab notebooks) in accordance with academic practice; research data is often kept much longer than financial records, since it may be needed to confirm research findings or for future study.
Disposition of Records: After the retention period expires, records that are no longer needed should be disposed of securely. Paper records should be shredded or incinerated, and electronic records should be deleted in a way that they cannot be recovered, to protect any confidential or sensitive information. However, before disposing, the office should double-check that no pending audits or legal holds apply to those records.
Historical Value: Some records or work products may have historical or scientific value beyond the retention period. The CSUSB may choose to preserve certain data sets, reports, or documentation for archival purposes or future research reference. Decisions to preserve beyond required periods might involve the CSUSB Library or Archives.
Sponsor Requirements: If a Sponsor has specific record retention or access requirements (for example, some contracts require the CSUSB to retain records for a sponsor inspection for a certain number of years, or to transfer certain records to the sponsor at closeout), the Sponsored Programs Administration will ensure those are followed. Often federal contracts incorporate the Federal Acquisition Regulation (FAR) clauses that specify record retention and government rights to examine records.
Access to Records: During the retention period, authorized representatives of the Sponsor, auditors, and other government officials (for federal awards, offices like the Inspector General or GAO) have the right to access pertinent records for examination. CSUSB and/or UEC will facilitate such access, provided the requestors have proper credentials and the request follows proper legal/process channels. Confidential records, including sensitive data received from community partners, public agencies, human subjects, or other third parties, shall be accessed only by authorized project personnel and disclosed only in accordance with applicable law, award terms, institutional approvals, and any applicable confidentiality agreement, data use agreement, nondisclosure agreement, IRB protocol, or other binding restriction on access or use.
Project Closure Procedure: Upon closing a project, the Sponsored Programs Administration will typically compile a checklist ensuring all reports are done and files complete. At this time, they may also prepare the records for storage (boxing physical files, confirming digital files are in a shared drive or archive) and note the destruction date per the schedule.

By systematically managing records, CSUSB and UEC protect each institution and the PIs in the event of future questions and demonstrate adherence to all requirements. Good recordkeeping is a foundation of compliance – it provides the evidence of all the diligent work done as outlined in this policy.

Conclusion:

This policy provides a comprehensive framework for the administration of sponsored grants and contracts at CSUSB and UEC, incorporating all necessary procedures and internal controls to comply fully with 2 CFR 200 (Uniform Guidance) and other applicable regulations. All CSUSB and Auxiliary personnel involved in sponsored programs are expected to understand and fulfill their responsibilities as outlined. By following this policy, CSUSB will ensure responsible stewardship of sponsor funds, maintain eligibility for future funding, and support an environment that fosters research and creative activities in alignment with the CSUSB’s mission.