The Single Audit Act of 1984 first established requirements for audits of entities that received federal funds, which was then extended to nonprofits through the Office of Management and Budget’s Circular A-133 “Audits of Institutions of Higher Education and Other Non-Profit Organizations. Due to revisions over the years, the current audit threshold is for entities that expend $750,000 or more in a fiscal year, which Princeton does many times. The annual external audit focuses on internal controls as well as compliance with the annually-updated Compliance Supplement.

Princeton’s external audit is completed by PricewaterhouseCoopers. Princeton is routinely audited by specific sponsors, and SRA is subject to audits and reviews by the Office of Audit and Compliance. Should a department or PI be contacted by a sponsor regarding a audit, please contact your SRA analyst immediately to share the information received, as all external audits should be managed centrally.

Cost allocation is the process of assigning a cost, or group of costs, to one or more awards in a reasonable proportion to the benefit provided to each award. If an expenditure solely benefits one award, it should be charged entirely to that award. However, sometimes an expenditure can benefit more than one award or activity. When this occurs, the expenditure must be charged in the same proportion as it benefits each of the awards or activities.  

At Princeton, various allocation methods are used based on type of expenditure. For more information, please see the Princeton University Direct and Indirect Costs Policy and the Cost Transfer Policy.

A cost transfer is defined as the transfer of an expense to a federally-funded sponsored project after it was initially charged to another sponsored project or a non-sponsored chartstring. Every effort should be made at the outset to charge all direct costs (e.g. salaries, lab suppliers, equipment, etc.) to the appropriate sponsored award, but sometimes cost transfers are necessary. To be allowable, a cost transfer must comply with federal regulations, sponsors' award terms and conditions, University policies, and be clearly documented.

For more information, please see the Cost Transfer Policy.

Federal requirements regarding proper internal controls on grants and contracts require effort certification by principal investigators (PIs) to ensure salaries and wages charged to federal awards are commensurate with the work performed. Princeton uses the web-based Labor Accounting (LA) Effort Reporting System for reporting and certifying effort. The web-based system significantly reduces the administrative burden of the effort reporting process.

For more information, please see the Effort Certification on Sponsored Projects Policy.

The Fly America Act of 1974 A federal law (Title 49 U.S. Code, Section 40118) established a legal requirement that all government-financed air travel be performed by U.S. air carrier services where such service is available. All flights (domestic and international) supported with federal funds must be taken on U.S.-flag air carriers, regardless of cost or convenience—unless an exception, as listed in the Federal Travel Regulation (FTR), is authorized.   

Important Note: Under the Fly America Act, domestic travel includes travel within and between the United States, its territories and possessions. Travel outside these specified areas is considered international travel, including travel to Canada and Mexico. There are some federal agencies that treat travel to Canada and Mexico as domestic travel for award budgetary purposes, but this treatment doesn't exempt travel to these countries from the Fly America Act.

Find important compliance information related to booking with World Travel, Concur, and other sources, and review Fly America Act exceptions.

Salaries budgeted and charged to NIH awards must comply with the NIH salary cap. The Labor Accounting (LA) system distributes costs to one or more chartstrings by amount, percentage, or full-time equivalent (FTE) for most regular employees’ normal compensation. The LA system has system logic that will display an error message when it identifies an LA distribution being paid to a person on a NIH project with a salary over the NIH salary cap. 

For current and historical information on the applicable salary cap for each fiscal year, please see the OER Salary Cap Summary webpage.

Princeton is committed to conducting its academic and administrative responsibilities in an ethical manner and in accordance with applicable laws, regulations, and University policy. The University not only expects, but depends on the community to share in this responsibility.

A University Hotline is available to report non-compliance (anonymity optional) or to ask questions regarding compliance issues.

Princeton University’s institutional Travel Policy generally governs the reimbursement of research-related travel expenses. However, faculty and staff members with awards that provide support for travel expenses should adhere to the travel guidelines as outlined in their particular award agreement and the Office of Management and Budget 2 CFR Part 200 (also known as Uniform Guidance). When the sponsoring agency imposes more restrictive travel regulations than University and federal guidelines, the sponsor’s travel guide must be followed. Only the funding agency has the authority to allow any exceptions to agency policy. If a PI wishes to obtain the sponsor’s approval of an exception to agency travel rules, they should send a written request to the sponsor via ORPA for prior approval.

For more information, please see the Travel Policy.

The Uniform Guidance Procurement standards for federally-funded purchases went into effect July 1, 2018. For federally-funded high-dollar purchases ($250,000 or more), a formal, public, request for proposal (RFP) and cost/price analysis are required. Princeton’s Procurement Services can assist with these on your behalf. In addition, for any noncompetitive (sole source) purchase of $10,000 or more, the supplier’s profit must be identified as a separate component of the total price. When obtaining quotes or bids from suppliers for federally-funded purchases, it is necessary to ask the supplier to include profit as a separate line item in their proposal.

All requisitions valued at $10,000 and above have a link to an electronic form, and notify the user if not completed prior to submitting the requisition. To learn more about creating requisitions valued at $10,000 and above, visit the Information for Purchases of $10,000 or More  page.