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Even before you apply for the award, OCG Compliance can, in conunction with your proposal analyst, guide you through requirements to identify resources you need.

Certifications & Representations

Sponsors often require CU to certify to the University’s processes and procedures used when managing funding. CU is generally required to certify to these before the University is able to receive project funding.ÌýExamples of certs and reps asked for include the certification of:

• the University’s cost accounting standards,
• a drug-free workplace,
• a whistleblower policy,
• funds received will not contribute to any lobbying efforts,
• employees who have been suspended, debarred or charged with criminal activity are notÌýallowed to administer federal funds on behalf of the University.

Property/Fabrications

Budget justifications and scope of work should include detailed information as to how the proposed property and equipment purchases are reasonable, allocable, and essential for the performance of project.

Since Department Administrators, OCG and other central offices assist Principal Investigators (PIs) with the management of property and equipment purchased with University funds, having such information accessible at the beginning will make purchases more seamless later on.

OCG Compliance can help PIs and Department Administrators understand whatÌýallowable costs are included in fabrications.

Learn more about Property and Fabrications.

Restricted Research Guidance

For some projects, CU is required to meet additional security requirements as outlined by the Federal Government.Ìý The OCG Compliance team provides guidance for PIs and Departments in navigating additional requirements of restricted research.Ìý

Contact Justin Mack for Restricted Research Guidance.

Borrowing or Lending (Bailment Agreements)

A bailment agreement is a legal agreement that documents the terms and conditions of property loaned between two entities. While title to the property is not transferred, a bailment agreement will document the period of the loan, transfer process, insurance and other relevant conditions of the loan.

If equipment is going off campus, contact the Property Accounting Office. OCG Compliancecan assist in determining whether a Bailment Agreement is needed or if there are restrictions.

Fabrications

A fabrication is the transformation of materials, non-consumable supplies and hardware into a one-of-a-kind piece of equipment or scientific instrument that meets a unique research need. Fabrications are considered capital equipment when they have an acquisition cost of $5,000 or more and a useful life of at least one year.

Sponsored Property Restrictions (purchasing, use, and disposal)

OCG Compliance provides specialized expertise and support to PIs and Departments in navigating the terms and conditions associated with sponsored project property including any restrictions for purchasing, use and disposal. The Sponsored Projects Property Control Manual captures CU Boulder campus’ policies, processes and procedures for property acquired on sponsored awards. Contact ocgproperty@colorado.edu for assistance.

Reporting

OCG Compliance is responsible for providing property reports to the sponsor, when required by the terms and conditions of the award. These include annual reports to agencies, national labs and federal flow-through sponsors at federal fiscal year end. Even if there is no property accountable on an award, the university may still be required to provide a report to the sponsor.

Research compliance is multi-faceted and OCG Compliance helps connect the dots to successfully fulfill obligations associated with sponsored projects. Contact us about any of these topics:

• Federal and State Regulations
• Sponsor Requirements/Clauses
• Order of Precedence
• International Travel/Fly America Act
• Federal Security Regulations
• Audits

Deliverables are frequently reports that are required by the sponsor. Reports must be submitted in a timely manner in order to meet the terms and conditions of the award. OCG Compliance assists PIs with submissions and provides guidance on sponsor requirements and expectations, as each sponsor has their own requirements. OCG Compliance also tracks all deliverables, including semi-annual, annual, final and other reports. These reports are saved into the official award record in infoED under Deliverables.

Technical

The Principal Investigator (PI) is responsible for completing and submitting reports required by the Sponsor that disclose: progress on the project research performance, milestone achievements, and new technology or invention developments. These reports may be referred to by the sponsor as:

• RPPR (Research Performance Progress Report)
• Technical Report
• Performance Report
• Project Report

These reports are considered deliverables under the terms of an award and should be submitted by the sponsor’s deadlines.

Patents and Inventions

Invention reports may be required in documents separate from other reports. If a patent or invention report is required, please contact ocgcloseout@colorado.edu so that OCG may complete and sign the required form. The PI will only need to advise whether or not there were any patents or inventions.

Property Reporting

OCG Compliance and the department will collaborate onÌýproperty reports to the sponsor, when required by the terms and conditions of the award. These include required reports to agencies, national labs and federal flow-through sponsors at federal fiscal year end. Even if there is no property accountable on an award, the university may still be required to provide a report to the sponsor.

At the end of the award, OCG Compliance works with the PI, the department, accounting and the sponsor to facilitate the closeout of the award. Generally, all projects must be closed out within 90 days of the award end date.

Requirements for award closeout are determined by Federal Agency standards and the specific award terms and conditions. OCG Compliance supports Principal Investigators (PIs) and departments with the administrative closeout of a sponsored award, including submission of final technical, progress, patent, and property reports.

Financial closeout of an award—including submission of financial reports and invoices—is managed byÌýthe Campus Controller’s Office.

The PI, Grant Accountants and OCG Compliance Officers may be required to complete and submit the specific final reports described below:

• Subs
• Reports
• Final deliverables
• Property
• Financial