Post-Award Issues for the Pre-Award Administrator by tpb23050


									Post-Award Issues for the
Pre-Award Administrator
                Tim Leung
        Senior Research Accountant
            Stanford University

              Craig Johnson
           Compliance Analyst
         University of Washington

            Csilla M. Csaplár
         Contract & Grant Officer
           Stanford University
• 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
• 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
• 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
• Invoicing
  – Format and documentation
     • Standard or Sponsor-specific?
     • Back up documentation required (negotiate!)
  – Tied to award type - Cost reimbursement or fixed
  – 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
             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
               Sticky Award Terms
• Publication
   – Restrictions
   – Impacts: restriction on ability to disseminate research results
• Export controls
   – Acceptance of controlled or proprietary technology, items covered by
   – 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.)
• 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
• 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
• Learn about and anticipate the needs of your post-award
• 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
• 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
• Ask questions – communication is key
• Be flexible! Not all sponsors and
      awards are created equal.
                             Tim Leung
           Senior Research Accountant, Stanford University

                             Craig Johnson
             Compliance Analyst, University of Washington

                          Csilla M. Csaplár
             Contract & Grant Officer, Stanford University

With thanks to Marti Dunne, New York University, and Diane Barrett, University of Wisconsin.

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