Contracts & Financial Compliance
The CALS Office of Contracts and Financial Compliance oversees domestic and international contracting and financial internal controls for the college, serving as the liaison between college faculty and staff and central business units.
Contracts
If you have a contract that needs to be reviewed, or need a contract and don't know where to start, click here to complete the CALS Contract Intake Form and we will be touch with next steps.
Questions on the below contract types should be directed to the appropriate office:
- Gifts/Donations - Alumni Affairs & Development
- Sponsored Funds - CALS Office of Sponsored Research
- Travel or Procurement of goods or services (other than international individuals) - Shared Services Center
Request for Late (over 60 day) Travel Approval
Plan ahead! Allow weeks to months for the contracting process, depending on the complexity of your agreement.
More detailed information and helpful links for specific contract types can be found in the below sections.
Are you thinking about launching an international academic collaboration—or formalizing an existing partnership? You have a number of options if you and one or more international peers are working together with no monetary exchange. Some types of collaborations do not require formal written agreements. If you think your academic collaboration may require a legally binding agreement or you received a contract from a collaborator, click here to complete the CALS International Contract Intake Form
Examples of International non-monetary collaborations:
- Relationships governed by memoranda of agreement (MOA), project agreements (PA), letters of intent (LOI), letter agreements, memoranda of understanding (MOU), and similar agreements regardless of title
- Scholarly exchange agreements between Cornell and international universities, governments, or corporations
- Student exchange or dual degree programs
International Collaborations Dashboard - use this searchable map to explore Cornell's more than 210 active memoranda of agreement with foreign institutions and NGOs.
Conducting Research in Indonesia - guidelines for Cornell affiliates who need an LOA or MOA/MOU to support an application for a foreign research permit to conduct research in Indonesia—including Fulbright and Fulbright-Hays.
International Independent Contractors are individuals that reside or perform services outside of the United States and provide personal services to Cornell, while retaining control over the means and methods of accomplishing the result.
If you plan to hire an individual to perform services outside of the US click here to complete the CALS International Contract Intake Form
Examples of revenue-generating activities include but are not limited to:
- Relationships governed by master services agreements (MSA), statements of work (SoW), educational services agreements, and similar agreements regardless of title
- Revenue-generating activities that fall outside sponsored research, including executive education, training, etc.
- Please consult CALS OSR if you're not sure if your project would be considered sponsored.
- Non-degree program tuition or service revenue
Non-gift, non-sponsored revenue from foreign entities requires specific contract terms and federal reporting. If you have an activity that will generate revenue for Cornell from a foreign entity click here to complete the CALS International Contract Intake Form
Learn more about Cornell's policy on reporting foreign gifts and contracts
Gifts and Endowments are managed by Alumni Affairs and Development
Sponsored Funds including Program Income pre-award begins with the CALS Office of Sponsored Research
RPTAs are very limiting transactions. Our primary focus at CALS is Fundamental Research and Extension. Fundamental Research is defined as basic and applied research activities, including trials, conducted to further the mission of Cornell University. Almost all agreements with industry are categorized as "Fundamental" and should be managed by the Office of Sponsored Research and Sponsored Financial Services. In rare cases, a Testing Services Agreement may be applicable.
For further information visit the Routine Testing Agreement website or contact Mandy Kafka (ajk287 [at] cornell.edu (ajk287[at]cornell[dot]edu)).
Director of Contracts and Financial Compliance
- (607) 592-5023
- jaf54 [at] cornell.edu
Financial Compliance
Internal controls are processes and practices designed to provide reasonable assurance of reliable financial reporting, the effectiveness and efficiency of operations, and compliance with laws, regulations, and policies.
The sections below explore internal control subject matter in more detail.
College oversight protocol
The college Office of Finance and Administration is responsible for maintaining documentation of internal control policies, procedures, and best practices, and serves as a subject matter expert and resource for college faculty and staff. The college will review and update this documentation at least annually and will communicate and train on any substantive changes.
The college will perform periodic internal reviews of department processes, respond to department FRS and manager questions or concerns, and work with central offices to ensure compliance with university policies.
University Policy 3.26, Financial Internal Controls
College Internal Controls
Account monitoring is the process of periodically assessing an account balance and transactions for allowability, allocability, and reasonableness, and investigating any unexpected results. This responsibility is shared by PIs, project personnel, unit managers and finance staff, and must occur regularly and be tracked in an auditable system.
Click here to download the full CALS Account Monitoring Guidelines (PDF)
Requirements
- All funds should be monitored monthly for allowability and allocability. Sponsored (CG) and Federal Appropriation (APFEDL) funds must be monitored no less than every two months. All other funds (GN, RG) must be monitored no less than quarterly.
- Units must have written documentation of account monitoring procedures, including how often reviews are performed, by whom, and where they are stored.
CALS Account Monitoring SOP Example
Process
The college best practice for account monitoring is to use the Post Award Administration dashboards within the Oracle Analytics Dashboards. Units may use any other reasonable, auditable method as long as the process meets all above requirements.
To monitor an account, you must understand the purpose of the account, then visually or electronically scan the activity posted for reasonableness. Anything found to have charged an incorrect account must be corrected as soon as the mistake is discovered.
Click here to download the full CALS Account Monitoring Guidelines (PDF)
University Policy 3.14, Business Expenses
DFS Account Monitoring Guidelines (part of the Internal Control Manual)
Cost Transfers on Sponsored Awards
The university must ensure that all charges meet the standards of allocability. This responsibility is shared by PIs, project personnel, and unit and central staff whose systems of controls require regular review of sponsored accounts. This occurs at the time an expenditure is requested, when a charge is posted, and verified through routine and closeout monitoring.
Through routine account monitoring, any charges found to have charged an incorrect account will be discovered and corrected in a timely manner. Cost transfers over 90 should be rare and must be supported by strong justification of the delay.
Required cost transfer documentation includes a description of the cost(s) being transferred, including why and when the original charge(s) occurred, why the receiving account was not originally charged, why it is appropriate to charge the receiving account, and that any systematic or administrative deficiency that caused the need for the transfer has been addressed if applicable.
University Policy 3.20, Cost Transfers on Sponsored Agreements
Salary Confirmation
The university requires annual salary confirmation for individuals paid with sponsored funds (CG), federal appropriations (APFEDL), or committed cost sharing. This after-the-fact certification of salaries by position does not replace routine monitoring.
The PI is responsible for ensuring appropriateness and accuracy of all salary expended on sponsored projects and notifying unit business staff of the need for updates to the salary distribution system, as changes become known.
Routine account monitoring includes closely monitoring effort commitments through the year and verifying that effort allocated to project accounts accurately reflects effort expended by project, that salary and benefit expenses match approved budgets, and that all committed cost share is recorded appropriately, including salary over the NIH salary cap.
Any salary found to have charged an incorrect account must be corrected as soon as the mistake is discovered, following the university cost transfer policy. Known adjustments or cost transfers of salaries and wages must be processed before effort has been certified through the salary certification process.
Faculty and research personnel will report potential financial conflicts of interest (fCOI) related to research via the Office of Research Integrity and Assurance (ORIA)
All other potential COI will be reported through the college COI process.
COI covered by Policy 4.14, Conflicts of Interest and Commitment (Excluding Financial Conflict of Interest Related to Research)
All members of the Cornell University community are expected to conduct the affairs of the university in a manner free from real or apparent bias motivated by self-interest. Relationships that may provide opportunity for bias must be disclosed and appropriately managed.
Definition
Typically, a Conflict of Interest (COI) may arise when an individual has the opportunity or perceived opportunity to influence the university's business in a manner implicating personal gain or competitive advantage of any kind.
An individual is considered to have a COI when they, a member of their family, or a known business associate either:
(1) has an existing or potential significant financial interest or other material interest or relationship that impairs or might appear to impair the individual's independence and objectivity in the discharge of their responsibilities to the university; or
(2) may receive a financial or other material benefit from information confidential to the university.
Click here to download the full CALS Managing Potential Conflicts of Interest Guidelines (PDF)
Conflict of Commitment
A Conflict of Commitment arises when an individual undertakes external commitments that may burden or interfere with their primary obligations and commitments to Cornell. The university expects that individuals will take appropriate steps to prevent external activities and commitments from having an adverse impact on the performance of their university duties and obligations.
Disclosure Process
Any faculty or staff with potential COI that falls under this policy must disclose through the below link.
CALS Conflict of Interest Disclosure Form
Upon full reporting and disclosure of the circumstances, the college may approve a commitment or activity, provided that the conflict can be managed. In many cases, the conflict can be managed through disclosure and the establishment of appropriate safeguards. Circumstances that are not susceptible to effective conflict management may be prohibited.
It is essential for employees to disclose any potential conflicts of interest as they arise. As professional relationships change and evolve during the year, you are required to report your potential conflict before you enter into agreements or business relationships with a related party. Review related policies and COI disclosure forms to ensure all potential COI is disclosed appropriately.
Related Policies and Reference Information
Policy 4.14 Conflicts of Interest and Commitment
Policy 1.7, Financial Conflict of Interest Related to Research
Summary
Units are responsible for stewardship of all assets under their control, as well as recording and maintenance of capital asset records within KFS. This includes tagging new assets, editing assets as needed throughout the year, performing biennial physical inventory on all assets, and properly disposing of and retiring assets.
Each unit has at least one person assigned the CAM processor role in KFS, and these are the individuals responsible for managing their assets throughout the year. Contact map86 [at] cornell.edu (Mark Pluchino) to add or change your unit’s CAM processors.
Definition
At Cornell, a capital asset is an item that has a useful life of more than one year and a value of at least $5,000. Capital assets are permanent, tangible, and held for purposes other than investment or resale.
To determine the value of the asset, include the purchase price, transportation costs, installation costs, value received from a trade-in, and any other direct expenses incurred by the university in obtaining the asset.
Training, maintenance agreements, and warranty agreements are not considered part of the capital equipment cost and should be expensed.
Unit Responsibilities
- Exercise stewardship responsibilities over assets under its control.
- Report capital asset acquisitions in a timely fashion.
- Tag capital asset acquisitions when appropriate.
- Consult with Office of Risk Management and Insurance if additional insurance coverage is appropriate or required. Notify police as appropriate when an asset is stolen or otherwise missing.
- Conduct a physical inventory, verifying the existence and condition of all capital assets, and reconcile to university accounting records.
- Update asset locations in the Capital Asset Module throughout the year.
- Dispose of capital assets properly and initiate an Asset Retirement Global edoc in KFS.
Fabricated Equipment The value of a fabricated asset is equal to the total federal allowable costs associated with its construction. These costs include the following:
- Original invoice prices paid for components
- All costs for shipping, handling, in-transit insurance, and storage related to delivery and installation of the asset’s components
- All of the asset’s installation costs, including site preparation
- All testing costs
- All books, manuals, and training necessary for the asset’s initial operation
- Service charges from CCMR, LASSP, CLASSE, and Chemistry shop
See Policy 3.9 Capital Assets for detailed instructions on fabricating equipment
Reference Materials
Policy 3.4, Use of Cornell Vehicles
Kuali Financial System (KFS) Standard Operating Procedures
Division of Financial Services (DFS) Capital Assets Guidance
KFS/Dashboards access - contact Mark Pluchino (map86) or Chris Savino (cjs345) to add or remove:
- KFS User - Role 54
- KDW Staff Accounting - Role 3000014 (Dashboard access)
- KDW Staff Labor - Role 3000015 (please provide specific orgs)
- Salary Transfer Initiator - Role 10005 (please provide specific orgs)
- Capital Asset Manager (CAM) - Role 6 KFS CAM Processor and Role 100000473 Retire Multiple Asset User (capital asset manager)
Contact the shared-services-center [at] cornell.edu (Shared Services Center) to add or remove:
- eShop purchasing access
- Concur - org managers (department approval) or traveler delegates