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HIERARCHY OF POLICIES

In a sponsored project, there are a number of different policies that may apply to your award. This includes the sponsor's terms, conditions and award policies; federal guidelines such as Uniform Guidance (2CRF200), state specific policies and guidelines; and institutional policies. When one policies contradicts another policy, which one should you abide by to ensure you're in compliance? Below is the hierarchy of policies that takes precedence and the general rule to follow.

Hierarchy

1. INSTITUTIONAL POLICIES

SYSTEM POLICIES

UNT Health is one of many campus that makes up UNT System. As a system, there are overarching policies that apply to all campuses. These policies will take precedence over the campus level policies. Certain functions, such as Human Resource (HR), Information Technology (IT) and Purchasing are centralized at the system level. Below are some of the UNT System policies that are applicable for sponsored projects:

UNT HEALTH POLICIES

UNT Health policies build upon UNT System policies and adds more details for processes that are unique to UNT Health compared to other UNT campuses. Below are the UNT Health policies related to sponsored projects:

Governance Policies

1.102 Employee Ethics and Standards of Conduct
1.105 Records Management
2.101 Fraud, Waste and Abuse
2.103 Protection from Retaliation (Whistleblower)
2.107 Privacy
2.109 Integrity and Compliance Training
2.111 Conflict of Interest Disclosure
3.101 Information Security Policy

Finance Policies

4.101 Budget Principles
4.102 Accounts Receivable
4.104 Travel and Expense
4.105 Contract Administration Compliance

Research & Innovation Policies

8.101 Effort Reporting
8.102 IACUC Functions and Responsibilities
8.103 Intellectual Property
8.104 Protection of Human Research Subjects
8.105 Research Conflict of Interest
8.106 Research Integrity
8.107 Sponsored Programs
8.108 Use of Controlled Substances in Research
8.109 Research Security

You can find the travel guide and full list of UNT policies here: ALL POLICIES TRAVEL GUIDE

General Rule: Any institutional policies that are more restrictive will take precedence over other state, federal and sponsor policies. For example, if institutional policies require itemized receipts for actual employee meals reimbursement, that would take precedence over any state, federal or sponsor's policies that does not required an itemized receipt.

2. STATE POLICIES

State policies apply for any sponsored projects funded with state funds. State funds generally have more restrictions then general university funds, thus state policies often override university policies as the most restrictive policy. The Texas Comptroller of Public Accounts manages the Texas Grant Management Standards (TxGMS), which outlines financial administration rules, cost principles and audit requirements. Many of these policies closely align with federal uniform guidance (2 CRF200) while some are specific to the state of Texas.

Travel
Travel policies for projects with state funds may be different from institutional and federal award policies. Below are some state travel policies that are important to understand.

Reimbursement Rates

Fiscal 2026 Travel Reimbursement Rates:
♦ Automobile Mileage: 72.5 cents per mile (Jan 1 - June 30, 2026) | 76 cents per mile (July 1 - Dec 31, 2026)
♦ In-State or Out-of-State Non-Overnight Meals: Not to exceed $36 daily
♦ In-State or Out-of-State Overnight Meals & Lodging: Refer to GSA's Rate (See Federal Policies)

For more information, refer to the TexTravel page: TexTravel

Transportation Expenses

A state employee is entitled to be reimbursed for transportation expenses incurred to conduct state business.

Below are allowable transportation costs:
♦ Mileage in Personal Vehicle
♦ Travel between Residence and Airport (1 round trip plus airport parking).
♦ Flights
♦ Rental Vehicles
♦ Parking expenses
♦ Tolls
♦ Railroad
♦ Mass Transit (bus, taxi, etc.)

Unallowed Transportation cost:
⊗ Travel between Employee's Residence and Place of Employment UNLESS it is (1) necessitated by extraordinary circumstances AND (2) occurs outside the hours the employee is working. If an exception is claimed, both must be documented.
⊗ Personal/ Unofficial state business

Required Documentation:
◊ Number of miles traveled determined by point-to-point itemization
◊ Rental Vehicles Receipts MUST include the name of the company, the name of the employee renting the vehicle, the starting and ending dates of the rental, an itemization of expense INCURRED* and PROOF OF PAYMENT.
◊ Flight Receipts MUST include the name of the employee and airline, ticket number, class of transportation, travel dates, amount of the airfare, origin and destination and proof of payment.
◊ State Law does NOT require a receipt for reimbursement of travel by bus, subway, taxi and other mode of mass transportation. However, UNT Health travel policies may be more restrictive, thus you should refer to institutional policies.

*A vehicle rental quote is not acceptable documentation because actual expenses have not incurred.

Meals and Lodging Expenses

A state employee is entitled to be reimbursed for meals and lodging expenses incurred to conduct state business.

A state employee may only be reimbursed for his or her ACTUAL meal expenses not to exceed the maximum meal reimbursement rate for that location. The state travel expense reimbursement rate is NOT A PER DIEM. The maximum should not be claimed unless the actual expenditures equal or exceed the maximum allowable rate.

Unallowed Meals and Lodging Expenses:
⊗ Meal expenses incurred within employee's designated headquarters UNLESS it is mandatory and connected with training, seminar or a conference.
⊗ Tips or gratuities are NOT reimbursable UNLESS the mandatory service charge was imposed by an establishment and cannot be refused by the customer.
⊗ Purchase of alcoholic beverage
⊗ State (Texas) Hotel Occupancy tax charged by a commercial lodging if the employee fails to present a properly completed exemption certificate to the establishment.

Required Documentation:
◊ Meal Receipts are not required by law. A state agency may establish an internal policy requiring employees to submit receipts for meals as a condition of reimbursement. [See Institutional Travel policies regarding meal receipts]
◊ A lodging receipt MUST include the name and address of the establishment, name of the employee, single room rate, daily itemization of the lodging charges and proof of payment.

Increasing the Maximum Lodging Rate
Under certain circumstances, the maximum lodging rate may be increased. (1) A state employee may claim less than the maximum meal reimbursement rate and use the amount of the reduction to increase the maximum lodging reimbursement rate. (2) The agency (UNT Health) may determine that local conditions necessitate an increase in the lodging rate for a particular location. This determination MUST be documented and may be available upon request.

Sample Request Form: Increase Lodging Rate

Resource Information

TexTravel Website: TexTravel
Texas Grant Management Standards (TxGMS): Standards V2.1
TxGMS Review: TxGMS Review

Statewide Single Audit
Each year, the State Auditor's Office (SAO) conducts a Statewide Single Audit for the State of Texas. For the federal compliance portion of the Statewide Single Audit, the State Auditor's Office audits the Schedule of Expenditures of Federal Awards (SEFA) in relation to the ACFR. The Comptroller prepares the SEFA by using the self-reported SEFA data.

Federal Portion of Statewide Single Audit Report for the Year Ended August 31, 2025: Single Audit Report
Summary of Federal Expenditures by State Agency: SEFA

3. FEDERAL POLICIES

Federal awards encompass a wide variety of scientific research. As a result, the Office of Management and Budgets (OMB) created the Uniform Guidance (codified at 2 C.F.R Part 200) to help simplify the rules, cut waste or extra work for people who get federal funds and provide administrative, cost and audit rules.

Instead of creating specific rules that are too specific or rigid, Uniform Guidance provides a set of guiding cost principles that are applied to every federal federal. Below are the cost principles that you should know.

Factors affecting Allowability

Cost must meet the following criteria to be allowable under Federal Awards:
♦ Be NECESSARY and REASONABLE for the performance of the federal award
♦ Be ALLOCABLE
♦ Be CONSISTENT with policies and procedures that apply uniformly to both federally financed and other activities of the recipient or subrecipient.
♦ Be accorded CONSISTENT TREATMENT of direct and indirect costs.
♦ Be adequately DOCUMENTED

Reasonable Costs

A cost is reasonable if it does not exceed an amount that a prudent person would incur under the circumstances prevailing when the decision was made to incur the cost.

Consideration must be given to the following:
♦ Whether the cost is generally recognized as ordinary and necessary for the recipient's operation or the proper and efficient performance of the federal award.
♦ Sound business practices, arm's length bargaining
♦ Market prices for comparable costs
♦ Whether the individual acted with prudence
♦ Whether the cost represents a deviation from the recipient's establish written policies and procedures

The Prudent Person test is one of the test used by Auditors to determine whether an expense is reasonable and ultimately allowable.

Allocable Costs

A cost is allocable to a federal award or other cost objectives if the cost is assigned to the federal award or other cost objectives in accordance with the relative benefits received. This standard is met if the cost satisfies any of the following criteria:
♦ Is incurred specifically for the federal award
♦ Benefits both the federal award and other work of the recipient and can be distributed in proportions that may be approximated using reasonable methods, or
♦ Is necessary to the overall operation of the recipient and is assigned in part to the federal award in accordance with these cost principles.

When In Doubt: Document your basis for why the expense was allowable and allocable to the award. Would it pass the Prudent Person test? Why is it necessary and reasonable for the performance of your federal award?

The federal government has its own travel regulations. The U.S. General Services Administration (GSA) sets the daily lodging (excluding tax) and meals and incidental expense (M&IE) for travel within the United States. Otherwise known as the per diem rate, it sets the standard allowable amount for lodging and meals based on the geographical location. When international travel is required, the U.S. Department of State sets the Foreign Per Diem Rate by location. See below for details regarding travel regulations on federal awards:

Per Diem Rates

A standard rate applies to most of the continental United States. Cities not appearing in the Primary Destination List may be located within a County for which rates are listed.

Determine the Per Diem Rate for your Trip here: Per Diem
On the first and last travel day, federal employees are only eligible for 75% of the total M&IE rate.

When meals are provided by the government or included in a registration fee, you must deduct those meals from your M&IE daily allowance. For more information, see GSA's guidance: M&IE Breakdowns

POV Mileage Reimbursement

If you use your privately owned vehicle (POV) for official government travel, you may be reimbursed based on the mileage traveled.

See the GSA mileage Reimburse Rate: Mileage

International Travel Per Diem

The U.S. Department of State sets the per diem rate by location. When traveling internationally on federal funds, the foreign per diem rates by location determine the maximum cost allowed for lodging and meals.

One important difference between the foreign per diem rates and the GSA rate is the inclusion of taxes. The lodging portion of the allowance is based on average reported costs for a single room, including any mandatory service charges and taxes. The meal portion is based on the cost of an average breakfast, lunch and dinner, including taxes, service charges and customary tips.

Determine the Foreign Per Diem Rate for your Trip: Foreign Per Diem
When traveling aboard on federal funds, the Fly America Act requires travelers whose air travel is funded by the federal government to use U.S. Flag air carriers, regardless of cost or convenience.

Learn more about the Fly America Act: Fly America Act

Receipts and Documentation

For any official temporary travel destination, you must provide a receipt to substantiate your claimed travel expense for lodging and receipts for any unauthorized expenses incurred costing over $75 or a reason acceptable to your agency explaining why you are unable to provide the necessary receipt.

If there are no hotels available at the per diem rate, you may ask your agency to authorize expense allowance provision. Your agency may authorize or approve the maximum per diem rate of up to 300% of per diem for the location where lodging is obtained. You should also ensure you have checked FedRooms to confirm there are no rooms available at per diem in the area where you need to travel. This review should be documented and retained for audit purpose.

4. SPONSOR'S POLICIES, TERMS & CONDITIONS

Each sponsor may have specific policies, terms and conditions that may add or remove some layer of state and federal regulations based on the type of award. The terms & conditions listed in your award notification details the specific terms that was agreed upon.

Below are examples of several sponsors and their administrative policies that determines when prior approval is necessary.

Administrative Requirements

In general, NIH recipients are allowed a certain degree of latitude to rebudget within and between budget categories to meet unanticipated needs and to make other types of post-award changes. Some changes may be made at the recipient's discretions as long as they are within the limits established by NIH. In other cases, NIH prior approval may be required before a recipient make certain budget modification or undertakes particular activities.

NIH Standard Terms of Award
Federal Administrative requirements allow agencies to waive certain cost-related and administrative prior approvals; these are known as expanded authorities. One or more of these authorities may be overriden by a specific term or condition of the award.

Cost-Related Prior Approvals
NIH prior approval is not required to rebudget funds for any direct cost item that the applicable cost principles identify as requiring the Federal awarding agency's prior approval, UNLESS the incurrence of costs is associated with or is considered to be a change is scope.

Prior Approval Requirements
♦ Additional no-cost extension greater than 12 months
♦ Capital Expenditures (Construction, Land or Building Acquisition)
♦ Change in Scope
♦ A significant change in the status of the PI or senior/ key personnel named in the NOA
♦ Change in Recipient organization
♦ Deviation from Terms and Conditions
♦ Need for additional NIH funding
♦ Pre-award costs
♦ Rebudgeting from Trainee Costs

Significant rebudgeting is considered a change in scope, which require prior approval. Significant rebudgeting occurs when expenditures in a single direct cost budget category deviate (increase or decrease) from the categorical commitment level established for the budget period by 25 percent or more of the total cost awarded.

Link to NIH Policy: NIH Grant Policy Statement

Grant Award Modification

A Grant Award Modification (GAM) is a request to modify a key fact or detail about the award. There are three types of GAMS in JustGrants:
♦ Project Period extension
♦ Programmatic
♦ Financial

Recipients MUST submit a GAM for changes in scope, duration, activities or other significant areas awards. These changes generally include but are not limited to:
♦ Altering programmatic activities
♦ Changing the objective of the project or program
♦ Changing the project site or service area
♦ Changing key personnel
♦ Inclusion of cost requiring prior approval under 2.CRF 200.407 that had not previously been approved by the DOJ agency
♦ Transfer of funds budgeted for participant support to other budget categories
♦ Subaward activities not proposed in the application and approved in the federal award.
♦ Changes in the total approved cost-sharing amount.

Budget Modifications
A GAM may be initiated for a budget modification if the request is to modify an approved budget to reallocate funds among the budget categories. Award recipients MUST initiate a GAM for budget modification if:
♦ the proposed cumulative change is greater than 10% of the total award amount (does not apply to award less than $250,000).
♦ a proposed budget change affects a cost category that was not included in the original budget.

Link to DOJ Grant Financial Guide: DOJ Financial Guide 2024

Prior Approval for Budget Changes: When in doubt, reach out to an UNT Health OSP Post-Award staff. Post-Award may advise you to reach out to your specific award program officer for additional clarification.

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HIERARCHY OF POLICIES

1. INSTITUTIONAL POLICIES

SYSTEM POLICIES

General Administration Policies

General HR Policies

Fiscal Management Policies

Information Technology Policies

UNT HEALTH POLICIES

Governance Policies

Finance Policies

Research & Innovation Policies

2. STATE POLICIES

Reimbursement Rates

Transportation Expenses

Meals and Lodging Expenses

Resource Information

3. FEDERAL POLICIES

Factors affecting Allowability

Reasonable Costs

Allocable Costs

Per Diem Rates

POV Mileage Reimbursement

International Travel Per Diem

Receipts and Documentation

4. SPONSOR'S POLICIES, TERMS & CONDITIONS

Administrative Requirements

Grant Award Modification