The sponsored funding compliance framework is complex, necessitating partnerships across many university units, including departments, centers, schools, colleges, business units and SPA.
Investigators and SPA have the responsibility for assuring institutional compliance with myriad sponsor and program regulations while adhering to institutional practices. To be successful, both investigators and administrators must understand sponsor policies and the regulatory requirements that govern each award.
Application of these regulations begins at pre-award and is critical for successful award management.
Federal Regulations
The U.S. Office of Management and Budget (OMB) oversees the basic structure of award management for the federal government. OMB develops the regulations for all federal agencies from which individual agencies produce agency and program-specific rules and regulations.
2 CFR 200 – Uniform administrative requirements, cost principles, and audit requirements for federal assistance awards (aka, Uniform Guidance) is guidance to the federal agencies and serves as the foundation for developing agency regulations.
FAR – Federal Acquisition Regulations is a listing of the policies and procedures regarding government procurement actions (i.e., contracts).
Agency-specific Regulations
Federal agency regulations vary from agency to agency and by program within an agency, as well as by award type. For example, NIH and NSF have very specific policies that guide how grantees must manage their programs.
Federal Research Terms and Conditions
Several federal agencies have also adopted research terms and conditions (RTCs) to provide a common set of rules for implementing Uniform Guidance.
RTCs apply to research and research-related grants made by the participating agencies listed below to universities, with exceptions noted in their Agency Implementation Statements (PDF). These terms are typically incorporated into the award notice by reference.
- NSF
- NIH
- NASA
- DOE
- USDA NIFA
- Commerce
- Homeland Security
These RTCs are maintained on the National Science Foundation (NSF) website:
FDP Research Terms and Conditions
Research Terms and Conditions Prior Approval Matrix (PDF)
NIU Regulations
Every institution has its own systems, policies, and guidance for the management of sponsored programs. Public-controlled institutions of higher education, like NIU, have additional state regulations that must be followed.
NIU Policy Library
State of Illinois Grants Accountability and Transparency Act
The Grant Accountability and Transparency Act (GATA), 30 ILCS 708/1 et seq., adopts federal 2 CFR 200 (Uniform Guidance) and applies these federal rules to all State of Illinois grant awards. Pursuant to the Act, the Grant Accountability and Transparency Unit (GATU) has been established in the Governor's Office of Management and Budget.
Other Sponsors
Non-profit and commercial sponsors often have their own requirements, which the university follows in addition to its own rules and regulations.
Order of Precedence Pyramid
Taken together, these regulations form the order of precedence pyramid that apply to sponsored awards. Award terms and conditions take priority over general agency terms and conditions. At times, institutional policies and state laws may be even more restrictive than the award terms and conditions. In general, the most restrictive rules must be followed.
