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  • Open Comment Period: May 4 - May 15, 2015

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pczarn2@uic.edu Jul 29, 2016 2:26 pm

Mandating that charges are to be processed within 30 days is not realistic for service center units who are already under staffed who process a large quantity. I believe increasing this to a 60 day window will allow sufficient time. You also need to have exceptions to this policy when a service center unit starts a service in advance of receiving the CFOAP while the contract is being negotiated.

pczarn2@uic.edu Jul 29, 2016 2:26 pm

I agree completely with the comments made by others.

Requiring the unit responsible for a self-supporting activity to cover the cost of unreimbursed charges is a sufficient incentive to encourage timely billing, without having to impose a monthly billing mandate. Monthly billing is too labor intensive, and thus costly, to be workable in every situation. We would have to increase our charges quite a bit if we had to bill monthly.

pczarn2@uic.edu Jul 29, 2016 2:26 pm

It seems to me that requiring the unit responsible for a self-supporting activity to cover the cost of unreimbursed charges should be a sufficient incentive to encourage timely billing, without having to impose a monthly billing mandate. Monthly billing is too labor intensive, and thus costly, to be workable in every situation.

pczarn2@uic.edu Jul 29, 2016 2:26 pm

200.343 Closeout: This section deals with the closeout of an award. I am unclear why this section justifies the requirement that units bill back monthly throughout the grant period, in lieu of quarterly? For under-staffed units, this will be a burden. Requiring units to get final charges billed to the project within 30 days following close of the project, is reasonable.

pczarn2@uic.edu Jul 29, 2016 2:26 pm

The following statement requires monthly billing: "To comply with this requirement, any self-supporting activity that provides goods or services to a sponsored project must bill the related project fund monthly." This would require a significant amount of work from a large fiscal and clerical staff and therefore is cost prohibitive.