Post-Award Issues for the Pre-Award Administrator
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Post-Award Issues for the Pre-Award Administrator Panelists: Tim Leung Senior Research Accountant Stanford University Craig Johnson Compliance Analyst University of Washington Csilla M. Csaplár Contract & Grant Officer Stanford University Agenda • Discussion of common issues (and solutions) that arise during proposal development and award stage that impact post-award • Terms and conditions to avoid • Ways to be proactive! • Building the bridge between pre-award and post- award to facilitate effective project management Budgets • Identify Cost Categories – Unidentified costs – May require sponsor approval for rebudgeting – Bottom line: Not in the budget? Ask. • Personnel Costs: Proposal vs. Expenditures • Materials/Supplies vs. Equipment • Subawards vs. subcontracts • Correct rates applied Budgets, continued • Budget projections • Impacts of poor planning: – Loss of direct cost funding available to the project – Loss of F&A/indirect cost recovery – Disallowances • Open communication reduces potential for: – Excessive, inappropriate, or late cost transfers – Manual adjustments – Disallowances – Revised invoices/financial reports – Audit findings – Loss of expanded authorities or letter of credit drawdown eligibility Awards • Award classification – award type, award instrument, sponsor type • Single PI vs. Multiple PIs – One shared account or separate accounts for each? – PIs from different departments/divisions – Access? Controls? • Budget years vs. cumulative project period – Separate accounts? – Is carryforward automatic or is prior approval required? Award Notices • Identify important information that post-award will need – Payment terms or schedule – Financial reporting requirements and timelines – PO or award number to be included on invoice – Restrictions – Milestones Award Set-up • Interest earned – Return to sponsor? – Use toward the project? – For use at institution’s discretion? • Tracking • Reporting • Interest Income – Tracked separately from revenue – Recorded as income, not expense • Cost sharing Award Set-up, continued • Period of Performance dates – Effective date vs. execution date – Funding authorizations • Budget periods • Incremental funding • Supplemental funding – Impacts allowability of expenditures • Rebudgeting – Institutional policy – Sponsor policy/prior approval requirements – Impacts ability to get reimbursed and project planning Billing/Invoicing • Invoicing – Format and documentation • Standard or Sponsor-specific? • Back up documentation required (negotiate!) – Tied to award type - Cost reimbursement or fixed price – Frequency • CR: in arrears monthly, quarterly, semi-annually, annually? • FP: up-front, per milestones reached, at completion? • Combination: tied to progress or deliverables? Payment Terms • Upon execution/initiation • Fixed schedule of installments • Milestone payments • Upon completion/termination • Withholding of percentage or amount • Net 30 standard • Non-standard can impact institution’s cash flow • Advances/refunds Reporting Requirements • Technical • Progress/interim • Final • Financial • SF 269 and SF 270 for federal awards • Sponsor-specific forms for others • Timeframe for submission – at least 60 days preferable • Who is responsible – department? Central post-award? • Be timely! Timely report submission impacts A/R, relationship between central offices with responsibility/oversight, and PI/institution’s reputation with sponsor • Delinquent reports may cause sponsors to withhold funding on all awards • Your institution may be identified as “not responsible”; can impact future competitions Sponsor Approvals • Rebudgeting • Carryforward • Change of PI or level of effort • Pre-award spending • Flowdowns – additional oversight Compliance Requirements • Waivers (PI effort, indirect costs) • Human/animals subjects approvals • Cost-sharing • Conflict of Interest • Impacts level of risk to PI, department, and institution Sticky Award Terms • Publication – Restrictions – Impacts: restriction on ability to disseminate research results • Export controls – Acceptance of controlled or proprietary technology, items covered by EAR/ITAR – Impact: loss of fundamental research exclusion • Intellectual property – Disclosure internally and to sponsor – Ownership – Impacts: loss of ability to file provisional patents, legal battles over inventorship if proper disclosures not made • Legal terms (indemnification, venue, governing law, etc.) Closeout • Meet with PIs before the grant period is over • Develop a process • Use checklists to track items of special concern (i.e. cost-sharing, unliquidated encumbrances, final invention statements, etc.) • Contact your grant accounting team in advance • Avoid “first among equals” thinking Terms to Avoid • Detailed financial reporting and back-up documentation • Payments or reporting in non-U.S. dollars • Reporting deadlines on end date of award (60 days after end date preferred) • Final invoicing deadline less than 45 days after end date • Monthly interim financial reporting • Return of all award funds if project is terminated early • Any restrictions on publication • Others? Be Proactive! • Training – PIs: Explain the process and your expectations, answer questions – Department administrators: Understand their role and the relationship with the PI, help facilitate the process with both – Encourage them to take advantage of training opportunities • Acting on behalf of the Institution – Explain the impacts of a poorly planned budget or a rushed proposal – Remind your team and your departments that you have their interests and those of the institution in mind • Get to know your neighborhood – Meet your customers! – Know who does what and who can help during a crisis • Be patient – and be a resource! Collaborative Solutions What Pre-award can do: • Serve as the primary point of contact for the PI, department, and sponsor • Learn about and anticipate the needs of your post-award counterparts • Understand impacts of award terms and conditions so you can negotiate the best deal for all the players • Educate your post-award counterpart on project specifics • Communicate often, and keep people apprised of your expectations • Recognize sponsor restrictions and special requirements, negotiate to standardize when it makes sense and is possible • Realize restrictions of institution’s systems, work to accommodate whenever possible Collaborative Solutions What Post-award can do: • Understand award terms and conditions, and how to adhere to them • Interact regularly, not just when there are fires to be put out • Ask questions – communication is key • Be flexible! Not all sponsors and awards are created equal. Questions? Tim Leung Senior Research Accountant, Stanford University firstname.lastname@example.org Craig Johnson Compliance Analyst, University of Washington email@example.com Csilla M. Csaplár Contract & Grant Officer, Stanford University firstname.lastname@example.org With thanks to Marti Dunne, New York University, and Diane Barrett, University of Wisconsin.