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Administrative (Non-Clinical) Policy
This administrative policy applies to the operations and staff of the University of Wisconsin Hospitals and
Clinics Authority as integrated effective July 1, 2015, including the legacy operations and staff of
University of Wisconsin Hospital and Clinics and University of Wisconsin Medical Foundation.
Policy Title: Federal & State Funds Policy
Policy Number: 1.20
Effective Date: May 1, 2016
To establish procedures for the review and approval of applications for Federal and State awards.
UW Health is required to establish and efficiently maintain procedures to assist staff in securing and using
Federal and State awards and sub-awards. Prior to submission to the granting agency, UW Health will
review the format and substance of application materials to determine compliance with Federal and State
The procedures listed below apply only to awards and sub-awards that would make UW Health a
recipient or sub-recipient (as defined below in III(B) and III(C)) if granted. They do not apply to
payments received for goods or services provided as a vendor (as defined below in III(D)). If you need
assistance making the determination of whether UW Health is a recipient or sub-recipient subject to the
procedures herein, please contact Fiscal Affairs: (608) 263-4909. However, please note-while potential
vendors awards are not subject to the procedures herein, those vendors’ awards must be reported directly
to Fiscal Affairs.
A. Federal/State Award
A grant, cooperative agreement, or contract that designates Federal or State funds for use by UW
A non-Federal entity that expends Federal or State award monies received directly from a
Federal-awarding or State-awarding agency to carry out a Federal or State program.
A non-Federal entity that expends Federal or State awards received from a pass-through entity to
carry out a Federal or State program, but does not include an individual that is a beneficiary of
such a program. A sub-recipient may also be a recipient of other Federal or State awards directly
from a Federal or State awarding agency.
Characteristics indicative of a Federal or State award received by a sub-recipient are when the
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1. Determines who is eligible to receive what Federal or State financial assistance;
2. Has its performance measured against whether the objectives of the Federal or State
program are met;
3. Has responsibility for programmatic decision making;
4. Has responsibility for adherence to applicable Federal or State program compliance
5. Uses the Federal or State funds to carry out a program of the organization as compared to
providing goods or services for a program of the pass-through entity.
Payment received for goods or services provided as a vendor is not considered a Federal or State
award. Characteristics indicative of a payment for goods and services received by a vendor are
when the organization/vendor:
1. Provides the goods and services within normal business operations;
2. Provides similar goods or services to many different purchasers;
3. Operates in a competitive environment;
4. Provides goods or services that are ancillary to the operation of the Federal or State
5. Is not subject to compliance requirements of the Federal or State program.
A. If UW Health would become a recipient or sub-recipient of the award, organize the following
application materials for approval by UW Health:
1. Proposal - this should be the grant application requested by the awarding agency.
2. Budget - this should match that submitted in the proposal to the granting agency, if
required. If not required by the granting agency, a budget should be prepared and
submitted to Fiscal Affairs; and
3. Operational Plan - this plan should include how the department intends to track revenue
and expenses and monitor costs for allow-ability including the person or position
responsible for these duties. This plan should include how the department intends to meet
any cost share or matching requirements. To monitor A-133 audit requirements, Fiscal
Affairs will need to be informed of revenue receipt and expenditures on a monthly basis.
B. Submit the Proposal, Budget, Operational Plan and contract/agreement (if applicable) for UW
Health review and approval to:
1. Principal Investigator,
2. Appropriate Vice President,
3. Chief Financial Officer, and
4. Legal Department
C. Any written contract/agreement should be per the Contract Approval and Signature Policy (4.01).
D. After approval of above parties, submit a copy of the approved materials to Fiscal Affairs for
E. Submit the required application materials to the granting agency.
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Sr. Management Sponsor: SVP, Chief Financial Officer
Author: VP, Finance & Controller
Approval Committee: UW Health Administrative Policy & Procedure Committee
President, University of Wisconsin Hospitals
Chief of Clinical Operations
Previous revision: 052013
Next revision: 052019