Purple Sheep CPE™

MODULE TITLE

Purple Sheep CPE™ — Post-Award Financial Stewardship (Post-Award) Module 2: Cost Principles as Control Systems: Interpreting Uniform Guidance in Practice

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PROGRAM IDENTIFICATION

Purple Sheep CPE™
Post-Award Financial Stewardship (Post-Award) Series™
1.0 CPE Contact Hour | Self-Paced Professional Education

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MODULE OVERVIEW

Cost principles are not regulatory references. They function as institutional control systems.

Within post-award environments, financial activity must consistently align with federal cost principles governing allowability, proper assignment to the project, and reasonableness. These standards are not passive requirements. They actively shape how institutions evaluate, approve, and monitor financial transactions.

This module provides a structured, risk-based examination of how cost principles operate as control mechanisms within institutional systems. It emphasizes how financial judgment, documentation, and oversight must align with Uniform Guidance to ensure sustained compliance.

Institutional exposure rises when cost principles are applied inconsistently, interpreted informally, or disconnected from internal control systems. These weaknesses create recurring risk because financial activity may proceed without sufficient validation, only to be challenged during audit or sponsor review.

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KEY AREAS OF FOCUS

This module examines:

• Cost principles as institutional control systems rather than regulatory references
• Application of allowability and proper assignment to the project within operational environments
• Financial judgment and its relationship to institutional risk
• Documentation expectations supporting cost decisions
• Strengthening compliance through structured control system design

These areas define whether cost compliance is sustained through systems or dependent on individual interpretation.

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PROGRAM STRUCTURE & INSTRUCTIONAL DESIGN

This module is structured to reinforce financial control system alignment and defensible decision-making.

The module includes:

• Scenario-based analysis reflecting real institutional cost compliance challenges
• Structured evaluation of control weaknesses tied to cost decisions
• Applied learning activities designed to assess financial judgment and documentation defensibility
• Knowledge validation through formal assessment

Topic structure follows the standardized Purple Sheep CPE™ model, including required engagement activities and a formal knowledge assessment to support audit defensibility.

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REGULATORY & COMPLIANCE ALIGNMENT

This module aligns with established regulatory and internal control frameworks, including:

• 2 CFR 200 (Uniform Guidance)
• ICH Good Clinical Practice (E6)
• Applicable FDA regulations governing sponsored and clinical activity
• COSO Internal Control Framework principles

Content reflects how cost principles are operationalized within post-award financial environments.

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LEARNING OBJECTIVES

Upon completion of this module, participants will be able to:

• Evaluate institutional exposure created through cost compliance breakdowns
• Assess whether cost principles are embedded within internal control systems
• Analyze financial judgment applied to post-award cost decisions
• Identify documentation gaps that weaken cost defensibility
• Determine whether cost decisions align with regulatory and institutional expectations
• Apply governance-based approaches to strengthening cost compliance systems

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COMPLETION & AUDIT VERIFICATION

Completion of this module requires:

• Full review of all instructional content
• Completion of required engagement activities
• Successful completion of the knowledge assessment

Participant progression and completion data are recorded to support institutional documentation and audit verification requirements.

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SERIES CONTINUITY

This module builds on the doctrine of award stewardship by defining how cost principles function as enforceable control systems within post-award operations.

It directly supports subsequent modules addressing:

• Financial monitoring architecture and active oversight systems
• Effort certification and labor-related compliance controls
• Award modification governance
• Closeout as control verification

The strength of cost control systems determines whether financial compliance is sustained or reactive.

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CPE STATEMENT

This module, combined with required engagement activities, represents 1.0 CPE contact hour.

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CREDENTIAL ALIGNMENT

This module is designed to support continuing education and professional development aligned with:

• Research Administrators Certification Council (RACC) expectations (CRA, CPRA, CFRA)
• Clinical research compliance and certification domains, including the Certified Clinical Research Professional (CCRP) credential administered by the Society of Clinical Research Associates (SOCRA)
• Clinical research competencies aligned with ACRP certification frameworks
• Internal audit and compliance competencies aligned with CIA principles

Module Access & Availability

Access to individual modules is provided for 90 days from the date of enrollment.

Individual modules are offered as part of the initial launch phase through December 31, 2026. Beginning January 2027, Purple Sheep CPE™ will transition to a series-based model designed to support deeper learning, stronger outcomes, and institutional alignment.