University Policy
Title
University of North Carolina Policy on Auditing Subsidies to Research Core Facilities
Introduction
Purpose
The University of North Carolina (“University” or” UNC-Chapel Hill”) requires clear and accountable management of subsidies that support research core facilities . This policy establishes the University’s expectations for committing, modifying, and auditing subsidies to ensure transparency and responsible stewardship of University resources.
Scope
This policy applies to all University departments, schools, and administrative units that commit institutional or departmental subsidies to research core facilities as part of the rate review and approval process.
Policy
1. Subsidy Commitments
During the bi-annual core rate review process, departments must review and approve each subsidy commitment and identify the funding source. Office of Sponsored Programs Cost Analysis and Compliance (OSP CAC) will document and track all commitments.
2. Subsidy Modifications
Any modifications to a previously approved Subsidy Commitment must be submitted in writing to the OSP CAC Team. This Subsidy Modification must be in writing and include:
- The effective date of the Subsidy Modification, and
- Confirmation that the core director has been informed of the change.
A modification is not considered official or actionable unless both conditions are met. If a department delays a modification and the core continues operating under the original subsidy, the department is responsible for covering the resulting shortfall.
3. Audit Process
At the end of the fiscal year, OSP CAC will audit all committed Subsidy Sources to verify that the total committed amount was transferred to the core facility in alignment with the approved rate proposal.
4. Audit Outcomes & Compliance
If the full committed subsidy has been allocated, no further action is required.
If the allocated amount falls short of the Subsidy Commitment, OSP CAC will notify the responsible department. The department must either:
- Complete a True-up Transfer by the end of the fiscal year, or
- Allow recovery of the shortfall from its Facilities & Administrative (F&A) return during the subsequent distribution cycle.
5. Enforcement
Departments that do not meet Subsidy Commitments or fail to submit timely Subsidy Modifications may experience delayed approval of future rate proposals, restrictions on subsidy eligibility, or increased administrative oversight.
Definitions
Research Core Facility: A shared research resource, administered by a department or center, that provides specialized services, instrumentation, equipment, or expertise in support of research and operates through a dedicated fee-based account to recover the costs of providing those services, with rates subject to university review under 2CFR 200.468.
Examples include shared laboratories or service centers that charge for access to equipment or technical services. Centrally funded research-support services are not considered core facilities under this policy.
Subsidy Commitment: A department’s approved and documented pledge to provide financial support to a core facility for a designated fiscal year.
Subsidy Source: The institutional or departmental funding source used to fulfill the Subsidy Commitment.
Subsidy Modification: A requested change to a previously approved subsidy commitment or effective date.
True-up Transfer: An internal transfer used to resolve a subsidy shortfall before fiscal year end.
Related Requirements
External Regulations
University Policies, Standards, and Procedures
Contact Information
Primary Contact
Name: Brian Bertlshofer
Title: Director of Cost Analysis and Compliance, Office of Sponsored Programs
Email: bertlsbj@email.unc.edu
Other Contact
Name: Meghan Kraft
Title: Director of Research Core Facilities, Office of Vice Chancellor for Research
Email: kraftmeg@unc.edu