The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) require that entities receiving federal grant funds develop written procedures minimizing the time elapsing between the drawdown of funds from the U.S. Treasury and disbursement by the entity (200.305 Payment). When federal funds are drawn down in advance of disbursement, they must be maintained in insured, interest-bearing accounts whenever possible.
DePaul complies with these provisions by operating all of its federal grant awards on a reimbursement basis. This practice ensures that no federal funds are drawn down in advance of actual expenditures. Upon receipt of a federal grant award, DePaul initiates an award setup procedure that results in the creation of a restricted grant account for the use of the Principal Investigator (PI). As part of this account setup process, university funds in the same amount obligated by the federal agency are made available to the PI as working capital. As the grant project is carried out, DePaul completes federal drawdowns on a quarterly basis to provide reimbursement for expenditures.
In those exceptional situations where a federal subrecipient lacks the working capital to operate on a reimbursement basis, limited advance payments are made to the subrecipient, but federal drawdowns are based on the disbursements reported by the subrecipient as it makes use of the funds. This approach ensures that no federal funds are drawn down by DePaul in advance of actual expenditures.
DePaul’s Office of Restricting Accounting is responsible for completing federal drawdowns in a manner that is consistent with these procedures.