Policies, Procedures, and Guidance

The 90 day policy calls for the posting of expenditures and other costs within 90 days of their occurrence. Posting these costs after 90 days of their occurrence will be permitted only on an exceptional basis, and with detailed justification that explains the error and/or delay in posting and supports the accuracy of the proposed assignment of costs.

Policy:

90 Day Rule

Related Guidance:

Over 90-Day Cost Transfer Justification Memo

The manual below outlines University policy with respect to the handling, receiving, transporting and depositing of cash. The term "cash" includes currency, checks, money orders, negotiable instruments and charge card transactions.  University funds are monies received from tuition, contracts and grants, (delivery of) revenues from University services, state and federal appropriations, gifts and all other sources of revenue or expense reimbursements, whether restricted or unrestricted as to purpose or use. All checks made payable to the University or any subdivision of the University are considered University funds.

Policy:

Cash Handling Policies & Procedures

There are four guiding principles or criteria used to determine whether a cost
can be charged to a sponsored agreement: reasonableness, allocability, allowability,
and consistency. These criteria apply for both direct and indirect (or Facilities &
Administrative) costs, which are defined in the policy below. For a given cost to be charged to a sponsored agreement, all four (4) of these criteria must be met.

Cost Allowability for Sponsored Charges

Expenses

Allowable Costs Quick Reference

Chart String Reconciliation Procedure

Cost Principles for Sponsored Projects Administration (presentation)

Faculty and Staff have a primary professional obligation to act in the best interests of Northwestern; their primary professional commitment of time and intellectual energies is expected to be toward supporting the University’s mission of education, research, and service. Considerations of personal gain from Outside Professional Activities or Financial Interests, as defined below, must not influence the decisions or actions of Faculty or Staff in performing their University responsibilities. This Policy outlines requirements for disclosure of Outside Activities and Financial Interests; educates Faculty and Staff about situations that generate Conflicts of Interest and Conflicts of Commitment; provides guidance to individuals and the University to manage or eliminate such conflicts; promotes the best interests of students and others whose work depends on Faculty and Staff direction; and describes situations that are prohibited.

Policy:

Conflict of Interest and Conflict of Commitment

Related Guidance:

Training

Northwestern University engages in cost sharing when it is in the best overall interest of the University, but limited to situations in which it is mandated by the sponsor per solicitation or policy guidelines, or deemed appropriate in light of specific and compelling circumstances. This document was developed to set forth University policy on cost sharing, and to provide guidance on the appropriate and consistent management and reporting of cost sharing throughout the lifecycle of a sponsored project.

Policy:

Cost Sharing on Sponsored Programs

Related Guidance:

What is Cost Sharing

Northwestern University must promulgate standards that are consistent with Office of Management and Budget (OMB) and Agency specific guidance. It is necessary to explain and justify transfers of charges onto Federal and non-Federal awards, from other Federal accounts, non-Federal accounts, or University accounts. Timeliness and completeness of explanation of transfer are important factors in supporting allowability and allocability, in accordance with the principles of 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”).

Policy:
Cost Transfers to Sponsored Projects

Related Guidance:

Cost Transfers

Salary Cost Transfer Journals: Documentation & Submission Steps

Over 90 Day Memo Approval Procedure for myHR Journals

Interim Email Routing and Approval Procedure for "Paper" Journals

Journal Processing

Over 90-Day Cost Transfer Justification Memo

Journal Entry Form

Cost Transfers: Best Practice Basics (presentation)

Payroll Journal Decision Tree

As a recipient of significant sponsored funds, the University must assure Federal and other sponsors that the assignment of time and associated salary and fringe benefit costs to the projects they sponsor is fair, consistent, and timely. The University’s effort reporting policies – along with related definitions, procedures, forms, data and technology – are the means by which this responsibility is fulfilled. Financial penalties, expenditure disallowances, and even harm to the University’s reputation could result from an inadequate effort reporting system or from failure to comply with effort reporting policies and requirements.

Policy:

Effort Reporting

Related Guidance:

Online Trainings

References and Tools

Capital equipment is tangible property having an acquisition value of $5,000 or more and a useful life expectancy of more than one year. Group purchases of tangible property that individually have acquisition values of less than $5,000 are not considered capital equipment and will be expensed. Fabricated equipment, which has an aggregate cost of $5,000 or more and a useful life expectancy of at least one year, is considered capital equipment. Repairs, maintenance parts or components, warranty costs, maintenance contracts or annual software licensing fees are not considered capital equipment and will be expensed.

Related Guidance:

Equipment Policy Manual

Capital Equipment Purchase Form

 

This policy outlines the requirements for Northwestern University to comply with requirements of the Human Subject Protection Program (HSPP), University Human Resource policies and practices, the Internal Revenue Service (IRS), and University purchasing and payment policies related to human subject payments.

Policy:

Human Subjects Payments

Related Guidance:

Human Subject Payment Flow Chart

IRB Guidance on Research Participant Payments            

A non-travel advance is money that is issued to a university employee for expenses that will be incurred due to University business. The funds are advanced under limited circumstances so that the employee will not have to use personal funds.

Policy:

Non-Travel Advances

 

Northwestern University engages with other organizations in a range of scholarly collaborations, many of which occur under the auspices of sponsored programs. Collaborating with other institutions can help Northwestern more effectively compete for and execute sponsored programs. When Northwestern is the Prime Institution (or Pass-through entity), subcontracting can increase risks associated with compliance and audit. Northwestern University is responsible for overseeing the programmatic and financial activities of Subrecipients, in the management of sponsored research. This document sets forth the University policy on subcontracting throughout the “lifecycle” of a sponsored program, which spans pre-award and post-award sponsored programs management.

Policy:

Subcontracting on Sponsored Programs

Related Guidance:

Subcontracts (presentation)

Subrecipient Monitoring Guidelines

All expenditures for travel, entertainment, and related expenses must support and advance Northwestern’s mission of education, research, and public service. This policy establishes minimum requirements for the approval and reimbursement of University-approved travel and entertainment expenses, as defined below. Each community member responsible for making decisions concerning such expenditures should always ask whether an expense represents an appropriate and worthy use of University funds. All travel and entertainment expenditures must be (i) documented as to business purpose, (ii) allocable to an appropriate funding source, and (iii) approved by an appropriate supervisor.

Policy:

Travel and Entertainment

Related Guidance:

NU Travel Website

Expense Reimbursements

Per Diem Guidance