Cost Accounting Guidelines: Roles and Responsibilities
For awards made before 12/26/14 which are not subject to the Uniform Guidance
Replaced by new guidance - 11/25/2014
When it is appropriate to seek approval for an exception to the standard principles that apply to costs, the responsibility for review and approval resides in the office of the dean or director of colleges and schools at UW-Madison. As indicated in RSP Notice 93-3 (dated 11/18/92), Financial Responsibility Policy for Extramural Projects, post-award administration is a shared responsibility among Principal Investigators, Department Chairs, Deans/Directors, and Research and Sponsored Programs. Under this shared responsibility, the delegation of the authority for review and approval of exceptions to the cost principles flows from the Director of Research and Sponsored Programs to the dean/director and/or their named designee in each college or school.
Deans/directors or their named designee(s), specifically the individuals who hold responsibility for review and approval of exceptions to the cost principles at the college/school level:
- need to be skilled in interpretation of the federal OMB Circulars which deal with cost principles and administrative requirements.
- need to be skilled in interpretation of sponsor application and award terms/conditions, as these may carry with them deviations from the federal OMB Circulars.
- may in some cases need to pursue written agency/sponsor approval of the exception, especially in unusual or highly atypical situations.
- are responsible for consistent evaluation and treatment of exception requests.
- are responsible for full and complete documentation of the exception request and approval.
- are responsible for timely review and approvals.
- in the case of denial, are responsible for providing clarity to PI and/or individual who submitted the exception request, to provide them with a clear understanding of the situation.
Financial responsibility for extramural projects ultimately remains with the Principal Investigator, the PI’s department/unit, and their college/school. If an approved exception is deemed unallowable at any time (e.g., during the active award period, during close-out, during a period of review or audit), the cost will revert back to the PI, the PI’s department/unit, and their college/school for recovery under an unrestricted source of funding.