3.2 Management of Project Expenditures

This policy summarizes some of the obligations imposed on Principal Investigators (PI) by federal regulation and by Stanford policy including quarterly review and certification of direct charges and cost-shared expenditures, annual certification of salary charges to sponsored projects, monitoring of funds within the sponsor's funding limitations and project closeout.


Questions about this policy can be answered by:

Bible, Sara

Associate Vice Provost for Research

Vice Provost and Dean of Research

(650) 723-9050

1. Principal Investigator Responsibilities

The PI has overall responsibility for the technical and fiscal management of a sponsored project. This includes the management of the project within funding limitations, adherence to reporting requirements and assurance that the sponsor will be notified when significant conditions related to project status change. This document addresses specific responsibilities concerned with the financial management of sponsored projects. While responsibility for the day-to-day management of project finances may be delegated to administrative or other staff, accountability for compliance with Stanford policy and sponsor requirements ultimately rests with the PI.

Stanford University requires all PIs to review their obligations for stewardship of sponsor funds and compliance with applicable regulations. For that purpose, specialized briefings are conducted. Individuals may also certify their review of this material by taking the course entitled "Stewardship and Compliance for Principal Investigators".

Back to top

2. Authorization of Direct Charges

To authorize the expenditure of funds to be charged directly to sponsored projects, the PI and originating department must assure that the:

  • estimated charge is reasonable and necessary
  • expenditure is allowable by the funding source and, if charged to a federally funded project, by OMB Circulars A-21 and A-110 or the Uniform Guidance
  • expenditure is allocable to the project, i.e., provides benefit to the project
  • funds are available within the authorized award amount and funding limitations
  • justification for the expenditure is documented
  • method of allocation of costs is appropriate and documented
  • charge is coded with the correct Expenditure Type and charged to the correct account [Project Task Award (PTA)]
  • charge has been processed through the appropriate University system
  • salaries and wages charged are reasonable in relation to the work performed and to the individual’s total payroll distribution
  • payroll charge to each sponsored project account does not exceed the effort devoted to that project 

Back to top

3. Stanford Base Salary

Stanford Base Salary (SBS) is the annual compensation paid by Stanford to individuals whose time is spent on research, teaching and/or other activities.

Stanford Base Salary:

  1. Includes regular and supplemental salary
  2. Excludes bonus payments and extra compensation such as faculty housing allowance, tuition reimbursement, etc.
  3. Excludes any income that an individual is permitted to earn outside of the Stanford responsibilities (e.g., consulting payments)
  4. May not be increased as a result of replacing Stanford’s salary funds with sponsored project funds

Back to top

4. Review of Project Expenditures

Expenditure Statements are the official record of project expenses and the basis for cost reimbursements to Stanford.

Expenditures for sponsored projects and cost sharing accounts must be reviewed by a knowledgeable individual, i.e., the PI or designee (typically the financial or research administrator) so that adjustments can be made in a timely manner, and that rates of expenditures can be monitored to assure availability of funds.  To be considered timely, monthly expenditures must be reviewed within two months of the end of the month being reviewed.  This review is documented by means of the reviewer's signature on the Quarterly Expenditure Statement (RM149).

Any questionable charges must be brought promptly to the PI's attention, and, if needed, corrected by an appropriate transfer. Transfers should be initiated as soon as possible after a need has been identified. Whenever expenses are moved to or between sponsored accounts, the PI must assure that the project that ultimately pays the expense is the project that benefited from that expense, and that there is adequate documentation to support the appropriateness of the transaction. Procedures governing transfers of expense are defined in RPH, Cost Transfer Policy for Sponsored Projects.

Back to top

5. Quarterly Review and Certification of Project Expenditures

Sponsored project and cost sharing accounts must be reviewed and certified by the PI quarterly. The following certification statement appears on Expenditure Statements for every sponsored project and cost sharing account:

The principal investigator confirms: to the best of my knowledge, salary and wages charged to this project are appropriate in relation to work performed on this project. All other costs charged to this project are, to the best of my knowledge, appropriate. Where required, corrections have been or will be made through the accounting system.

Project expenditures must be reviewed and certified every academic quarter, recorded by signature on the Quarterly Expenditure Statement (RM149). This certification is the responsibility of the project PI (or Co-PI). A PI may delegate the monthly review of expenditures for accuracy, but may not delegate certification of the appropriateness of the charges except as follows.  The PI may only delegate review and certification to a participating Academic Council member or PI eligible individual who is responsible for a portion of the statement of work and is identified as the Task Owner in the accounting system.

The purpose of the review and certification is to confirm that all expenses charged to the account are allowable, allocable to the project, and reasonable. The certification of salary expenditures confirms that salaries charged to the account are supported by a corresponding expenditure of effort during the time period being certified. The certification also assures that other expenditures are for items or services purchased and used during the project period as specified by the award. It is the PI's responsibility to seek a no-cost extension of the award if that is necessary in order to complete the project.

To be considered timely, the expenditure statement must be reviewed and signed within two months of the end of the academic quarter being certified.  A quarterly calendar detailing timeliness for both review of monthly expenditures and quarterly certifications of expenditures is available in the Related Items section of this policy.  Issues regarding the timely certification of expenditures should be discussed with the appropriate Department Chair, School Dean, and/or the Associate Vice Provost for Research or the Research Financial Compliance Services Office. 

Adequate explanation and documentation for all project charges must be maintained for four years after the sponsor closes out the award. Where documentation cannot be provided as to the allowability, allocability and reasonableness of any project expense, including but not limited to expenses incurred late in the project period, the sponsor may deny them. In this case, the PI, department or school will be expected to cover the expense from unrestricted sources.

Each school and independent laboratory must retain reviewed and certified Quarterly Expenditure Statements.

Any departure from the policy or procedures regarding summarization of Quarterly PI Review and Certification must be approved in advance by the Office of Vice Provost and Dean of Research (DoR) and Research Financial Compliance and Services Office (RFCS).

Back to top

6. Annual Certification of Salaries to Sponsored Projects

Federal regulations require certification of payroll distribution (total salaries and wages) for each faculty, staff, academic staff researcher (ASR), student and postdoctoral scholar whose Stanford salary is charged in whole or in part to one or more of the following:

  • federally sponsored projects
  • subawards with a federal prime sponsor where Stanford is a recipient
  • cost sharing accounts for federally sponsored projects
  • non federally sponsored projects that incorporate Office of Management and Budget (OMB) federal requirements (A-21 or the Uniform Guidance)

Faculty, and in rare situations designated certifiers, will review and certify employees’ payroll distribution on an annual basis beginning with calendar year 2013 salaries and wages using the eCertification system.  Prior to certification, the financial or research administrator shall review the annual payroll distribution for reasonableness. 

Faculty Self Certification

  • Faculty members and individuals with PI waivers who charge any portion of their salary to any funding sources listed above will review and certify their own payroll distribution.

PI Certification of Employees:

  • PIs will review and certify payroll distribution for staff, ASRs, students and postdoctoral scholars who perform work on his/her sponsored projects.
    • A PI may delegate the review of payroll expenditures for accuracy, but may not delegate certification of the appropriateness of the charges except as follows. The PI may only delegate review and certification to a participating Academic Council member or PI eligible individual who is responsible for a portion of the statement of work and is identified as the Task Owner in the accounting system.
    • In limited situations, the supervisor or other person with first-hand knowledge and/or suitable means of verification that the work was performed (designated certifier) will review and certify the payroll distribution. The Associate Vice Provost for Research must approve such exceptions.

Categories of Payroll Charges

The following payroll charges (salaries and wages) are to be reviewed and certified with the concept of reasonableness in relation to the work performed and to the individual’s 100% payroll distribution.  The PI or other designated certifier must have firsthand knowledge and/or suitable means of verification of the work performed and will review and certify the payroll distribution within the four categories as follows:

  • Sponsored Projects: Payroll charges for each employee will be reviewed and certified by account [(Project Task Award (PTA)].  The payroll charge to each sponsored project account may not exceed the effort devoted to that project.  However, the payroll charge can be less than the effort devoted to that project.
  • Cost Sharing: Payroll charges for each employee charged to a cost sharing account will be reviewed and certified by account.
  • Over the Salary Cap: Payroll charges in this category will be reviewed and certified in aggregate.
  • Non Sponsored Charges: Payroll charges in this category will be reviewed in aggregate based on an assessment of reasonableness in relation to the individual’s 100% payroll distribution.  The “Non-sponsored Charges” category may include the following:
    1. Faculty, Division, Departmental and School accounts that serve as a funding mechanism to supplement externally sponsored funding.  Payroll charges to these accounts represent additional effort/time expended that was not proposed or charged to sponsored accounts and will be considered in aggregate.
    2. Teaching responsibilities
    3. Preparation and submission of new and competitive sponsored proposals
    4. Non-sponsored research (funded by faculty, department, school or university funds)
    5. Clinical responsibilities
    6. Administrative responsibilities
    7. Other university responsibilities or activities

Review and Certification

The Federal Office of Management and Budget recognizes that in an academic setting, teaching, research, service, and administration are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate.  Stanford's acceptable degree of tolerance is +/-5%.

  1. An individual’s total payroll distribution/effort is equal to the total time spent on his/her university responsibilities.  Total payroll distribution/effort is not limited to 40 or any other specific number of hours. 
  2. Outside consulting is not part of an individual’s university responsibilities.
  3. Individuals are not required to maintain detailed time records of their actual work.

Certification Statement

After reviewing payroll charges information, PIs and other designated certifiers will certify:

To the best of my knowledge, the salary charges to individual sponsored projects and cost sharing accounts as well as the over the salary cap category and the non sponsored category are reasonable in relation to work performed under my direction.

If the payroll distribution for an individual is not reasonable or appropriate, the PI or designated certifier should not certify and should notify his or her research administration staff contact to make necessary changes. Review and certification must be completed by June 5, 2015.  Issues related to the timely certification of payroll distribution should be discussed with the Vice Provost and Dean of Research or the Research Financial Compliance Services Office. 


If a payroll adjustment is made to a previously certified employee's payroll distribution, the certifier may need to recertify that employee's payroll distribution per the instructions below.  

Sponsored Projects or Cost Sharing:

Payroll adjustments more than +/-5% for an individual sponsored project or an individual cost sharing account must be recertified unless the adjustment is within the same SPO number.

Over The Salary Cap Category or Non Sponsored Category

Payroll adjustments that impact the category total more than +/-5% must be recertified.  Changes within these categories need not be recertified if they do not impact the Sponsored Projects or Cost Sharing categories.

Recertification must be completed within one month of notification by Research Financial Compliance and Services. There may be additional circumstances where the Dean of Research Office or RFCS requires recertification. For more information see the Payroll Distribution Recertification Matrix in Related Items below.

Back to top

7. Charging Vacation to Projects

Staff at Stanford University, including Academic Staff-Research (non-faculty), accrue vacation as specified by University policy see below in Related Items Administrative Guide memo 22.5: Vacations. Stanford and the Office of Naval Research have established Vacation Accrual/Disability Sick Leave rates for exempt and nonexempt/bargaining unit staff. These accrual rates, reviewed and negotiated annually, enable Stanford to charge the appropriate funding source for vacation earned by benefits-eligible staff as they are working.

Back to top

8. Charging Proposal Expenses to Ongoing Projects

Proposal preparation costs are the costs of preparing proposals on potential Federal and non-Federal projects, including the development of data necessary to support Stanford's proposals.  These costs typically include salary for the PI and/or others. 

The cost of proposal preparation activities in support of new and competing sponsored proposals cannot be charged to sponsored projects except when explicitly allowed or required by the sponsor (e.g. NIH Mentored Career Development Awards).

The cost of proposal preparation efforts for a non-competing extension or continuing research may be charged to current related projects.

Work performed by faculty, academic staff researchers, instructors and regular staff that is related to current projects may also be related to new projects in development. Only the incremental effort associated with proposal preparation that does not benefit the existing project(s) needs to be identified and charged to an appropriate non-sponsored account.

Back to top

9. Monitoring of Funds within Sponsor Funding Limitations

PIs are responsible for the ongoing fiscal management of awarded projects, including regular monitoring against project period budgets. Federal grants policy (OMB Circular A-110) establishes the approved project budget as the financial expression of the project, and sponsors may evaluate the project against the budget at any time. Although sponsors allow certain flexibilities with respect to rebudgeting, unobligated balances, and preaward costs, Stanford University and sponsors expect expenditures to be reasonably consistent with the approved project and budget. Sponsors may question or restrict expenditures that appear inconsistent with the project plan and budget. PIs are obligated to request prior approval when budget and program plan revisions indicate a significant change in scope. Indicators of a change in scope can include, for example, significant expenditures beyond the amount authorized on the award, or requests for additional funding.

Back to top

10. Overdrafts

It is Stanford's expectation that projects will be managed within their established budgets. If, as a result of unusual circumstances or unanticipated project expenses, an account is in overdraft upon expiration of the term of the sponsored project, and if additional funds have not been received from the sponsor, the PI must identify an appropriate source of funds (e.g., gift, endowment, or operating budget) to cover the expense. The overdraft must be transferred to a cost sharing award in sufficient time to permit Stanford to comply with the financial reporting requirements of the original award (See Project Closeout, below).

The department must identify the source of funds to the Office of Sponsored Research or designated School office, which will create a cost sharing account. The department will then initiate the necessary expense transfer, including documentation of the nature of the expenses, noting they were legitimate project expenses but the funding was inadequate, and other reasons for the transfer. Such transfers must occur in sufficient time to permit Stanford to comply with the financial reporting requirements of Closeout, and the RPH: Cost Transfer Policy for Sponsored Projects.

The PI, department or school is responsible for the timely clearance of any unfunded expenditures from within its resources.

Back to top

11. No Cost Time Extensions

If additional time is needed to complete a project and there is an unexpended balance in the award, PIs may request that the period of performance of an award be extended. In some cases, Stanford officials are authorized to approve no cost time extensions; in other cases, agency prior approval is required. Requests for extensions should be initiated by a PI and processed in accordance with the terms of the sponsored award; in most cases, the countersignature of an authorized institutional office is required. To ensure compliance with the reporting requirements of awards, PIs are urged to submit no-cost time extension requests as soon as the need becomes apparent. Requests for a no cost extension should be submitted no later than the end date of the award (unless an earlier date is required by the agency.) Award closeouts cannot be delayed to accommodate pending requests submitted after the award end date.

If final technical reports are to be completed after the project end date, and funds from the project are available to pay these expenses, a no cost extension should be obtained from the sponsor to cover the expense of producing and distributing those reports. If funds are not available from the project, then the PI, department or school must identify unrestricted funds to pay final report costs.

Back to top

12. Project Closeout

PIs are responsible for overseeing the proper closeout of sponsored projects, including the timely submission of all required reports (including final technical reports). While central offices prepare and submit final administrative reports, including financial and property reports, they do so on the basis of documentation created in the department. PIs must assure that such documentation is adequate and readily available. In addition, PIs are responsible for ensuring that any necessary final financial adjustments and documentation (e.g., final invoices from vendors or subrecipients) are received promptly after the end of the award.

If an approval to close an award has not already been provided by the PI, the Office of Sponsored Research will prepare and submit financial reports based on the information reflected in the financial system. In addition, some financial reports may require the PI's signature.

Back to top

Go to RPH Chapter: