3702 (F)

UMB Policy on SPAC Federal Financial Reporting (FFR)

Financial Affairs   |   Approved August 24, 2024

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Responsible VP/AVP

Dawn M. Rhodes, DBA, MBA

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Purpose

To set forth the standards for University of Maryland, Baltimore (UMB), to provide accurate and timely Federal Financial Reports (FFR) and to ensure UMB meets the terms and conditions of sponsored awards.

Policy Statement

UMB will submit FFRs to external sponsored awarding agencies in a timely and accurate fashion using the information in the UMB financial system. UMB is required to disclose financial information as required by the terms and conditions of each sponsored award.

This policy alerts the research community to the urgency of timely submission of FFRs for sponsored awards. For all funds received from a sponsor, UMB agrees to financially manage federal funds in accordance with the Uniform Guidance found in 2 CRF Part 200 {Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards}. Federal agencies have become increasingly stringent about the timely submission of required financial reports as this is considered a key mechanism reflective of proper accountability and good stewardship of funding. Non-compliance with sponsored award reporting has adverse consequences including but not limited to, disallowing costs, withholding of further awards, wholly or partly suspending the grant, and audit finding risks.

1. Sponsored Projects Accounting and Compliance (SPAC) is the UMB department responsible for issuing FFRs to Sponsors.
   Instructions and guidelines preparation, submission, and deadlines for FFRs are set forth in UMB Procedure on SPAC Federal Financial Reporting (FFR) and UMB Procedure on SPAC Sponsored Award Closeout.
2. SPAC issues FFRs for expenses that have posted in UMB’s financial system. Any variance to those charges must be fully supported with documentation by the department responsible for the expense.
3. The department must return a signed annual and final FFR’ to SPAC at least ten (10) business days prior to the due date required by the sponsor to ensure timely submission.
4. If a department is unresponsive to the request by SPAC for a review and signature on the FFR, SPAC will meet the sponsor’s deadline using the expense that is posted in the UMB financial system on the day that the report is submitted to the federal government agency.
5. SPAC conducts periodic reviews to ensure that expenses included in the FFR are reasonable and allocable under the terms and conditions of the Sponsored Award and that the FFR is in accordance with UMB’s policies.
6. UMB employees who fraudulently create or submit an FFR to a Sponsor may be subject to disciplinary and/or criminal action.

Definitions

Financial Report – a form reporting the status of funds allocated by sponsors in relation to total direct and indirect costs at a point in time (i.e., quarterly, semi-annually, annually, end of award). A Federal Financial Report (SF-425) is a standard form required by most federal agencies to report the financial status of a grant or cooperative agreement.

Scope and Exceptions

This policy applies to Sponsored Awards received from external agencies where FFRs are required as stipulated in the award documents. Financial reports will be prepared based on UMB’s accounting records and submitted by SPAC.

There is further guidance on the final FFR in the UMB Policy on SPAC Sponsored Award Closeout.

Federal and State Student Financial Aid are excluded from this policy.

Individual fellowships do not require a financial report.

Roles and Responsibilities

SPAC Team

• Submit FFRs to external agencies timely and accurately.
•  Issue FFRs for expenses that have posted in UMB’s financial system.
• Conduct periodic reviews to ensure that expenses included in the FFR are reasonable and allocable under the terms and conditions of the award.

Schools/Department Administration

• Ensure allowability, allocability, and reasonableness of expenses against federal awards.
• Review costs on a monthly basis.
• Send supporting documentation for costs included in an FFR but not yet posted to the financial system.

Adherence to the departmental responsibilities in the UMB Procedure on SPAC Federal Financial Reporting (FFR) and UMB Procedure on SPAC Sponsored Award Closeout.