Cost Sharing Interest Agreement

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					             1



   INTRODUCTION
        TO
SPONSORED PROJECTS
  ADMINISTRATION
     November 12, 2009


    WELCOME!
              TODAY‟S TOPICS
                             2


Randy        Welcome, the research administration process,
             intro to OCG
James        Intro to SPA
Kathy        Definitions of Grant, Cooperative Agreement,
             Contracts, and Responsible Conduct of Research
Joan         Preparing and Processing Proposals
Joyce        Preparing Proposal Budgets
Jennifer     Award Negotiations, Set Up, and Management
Andrea/Mindy Subcontracts
Diane        Financial Oversight including A-21, A-110, A-133
Pat          Cost Sharing, JEs, Effort Reporting
Sandra       Billing & Cash Management
Diane        Close-out Procedures
                OBJECTIVES
                         3


 TO UNDERSTAND THE SPONSORED PROJECTS PROCESS
 FROM BEGINNING TO END

 TO UNDERSTAND THE MUTUAL RESPONSIBILITIES OF
 OCG, SPA, DEPARTMENT AND PI

 TO BECOME FAMILIAR WITH THE RESEARCH SERVICES
 AND RESOURCES AT UCB

 TO LEARN THE BASIC RULES AND REGULATIONS
 GOVERNING SPONSORED PROJECTS

 TO IMPROVE THE MANAGEMENT OF SPONSORED
 PROJECTS
    SPONSORED PROJECT: DEFINED
                                         4

   The proposal responds to a formal RFA, RFP, or other formal solicitation
    and the project is initiated by notice of award.
   The Statement of Work specifies programmatic objectives to be
    accomplished within a delimited period of time and budget.
   These awards require deliverables or detailed technical reports.
   These awards require separate accounting procedures and detailed financial
    reports.
   These awards include provisions for audit by the sponsor.
   These awards involve the disposition of property, whether tangible or
    intangible, that may result from the project.
   These awards require regulatory oversight in areas such as animal care,
    human subjects, bio-safety, or financial conflict of interest.
                      See APS Sponsored Project Revenues at:
      https://www.cusys.edu/policies/Fiscal/Rev_Sponsored-Project-Revenue.pdf
          5




    THE PROCESS:
FROM IDEA TO CLOSE OUT
PRINCIPAL INVESTIGATOR & DEPARTMENT
           RESPONSIBILITIES
                       6



  IDENTIFY FUNDING/COLLABORATION
  OPPORTUNITIES.
  NOTIFY OCG RE: PROPOSAL . . . EARLY.

  PREPARE PROPOSAL.

  OBTAIN ALL APPROVALS (C/S, SPACE,
  RELEASED TIME, etc.).
  REVIEW AND ACCEPT THE TERMS OF THE
  AWARD.
PRINCIPAL INVESTIGATOR & DEPARTMENT
           RESPONSIBILITIES
                      7



 IMPLEMENT THE S.O.W. ACCORDING TO THE
    AWARD TERMS.
   COMPLY WITH ALL REGULATIONS.
   SUPERVISE PROJECT PERSONNEL.
   MANAGE THE PROJECT BUDGETS.
   AUTHORIZE EXPENDITURES.
   PREPARE TECHNICAL REPORTS.
   WORK W/ SPA FOR FINANCIAL REPORTS.
   WORK W/ OCG FOR PROPERTY AND INVENTION
    REPORTS.
        OCG RESPONSIBILITIES
                          8

Provide Funding Information
Interpret Proposal Guidelines
Prepare Proposal Budgets, etc.
Submit Proposals
Review Awards/Negotiate Terms and Conditions
Establish Pending Accounts
Authorize Account Numbers
Assist with Project Planning/Start-Up
Prepare Subcontracts
Provide Administrative Oversight/Assistance
Provide Liaison with Sponsors
Provide Training
Maintain Data P/A Data Bases
       DISTRIBUTION OF OCG FUNCTIONS
                             (Who are you going to call?)
                                           9


Funding Information: Proposal Analyst                  Subcontracts: Andrea/Mindy
Proposal Assistance: Proposal Analyst                  OPAS Approvals: CGA
Budget Development: Proposal Analyst                   Changes in SOW: CGA
IDC Waivers: Randy and AVCR                            Changes in Budget: CGA
FastLane/Grants.Gov: Proposal Analyst                  CAS Exceptions: PA or CGA
Proposal Status: Proposal Analyst                      No Cost Extensions: Ted
Award Status: Contract & Grant Admin.                  Property Questions: Ted
Pending Account: Contract & Grant Admin.               Data Reports: Roger/Jan
Project Numbers: Contract & Grant Admin.               Contract Closeouts: Jan

                                        OR
                 Randall.Draper@colorado.edu (303-492-2695)
                Kathleen.Lorenzi@colorado.edu (303-492-2692)
University of Colorado at Boulder
Office of Contracts and Grants
Organizational Chart – Fall 2009                                        Director (1.0)
                                                                        Randy Draper

                                                             Program
                                                           Assistant (1.0)
                                                         Chandra Tjandrasa

                                                                         Associate
                                                                        Director (1.0)
                                                                        Kathy Lorenzi



                                                               DATA                                             POST-AWARD
              PRE-AWARD
                                                            MANAGEMENT

              Coordinator
                 (1.0)                                        Coordinator                 Student(s)             Coordinator
            Karen Springfield                                     (1.0)                  Amanda Todd                (1.0)
                                                            Roger McCormick              Joel Dickens           Jennifer Ward
                                     Work Leader (1.0)
   Proposal                            Joyce Kroll
                                                                                                                                    Work Leader (1.0)
  Analyst (1.0)                                                                                                                       Patti Young
  Laura Gehle                                                                                                   Award Processing
                                                                                          Contract/Grant
                                 Proposal                                                Administrator (1.0)    Work Leader (1.0)    Contract/Grant
    Proposal                    Analyst (1.0)              Reports Manager                 Edison Wolf           Johanna Eagan      Administrator(1.0)
  Analyst (1.0)                 Joan Eaton                 Coordinator (1.0)                                                          James Uhes
  Stefan Reiss                                                Jan Farrar                 Property/Travel(1.0)        Award
    Proposal                    Proposal                                                     Ted Jobe                               CGA/Subcontract
                                                                Data                                             Processor (1.0)
 Analyst (.75)                Analyst (1.0)                                                                                         Administrator (1.0)
                                                            Manager (1.0)                                          Lori Lafon
 Lisa Tedesco              Anselmo Serralheiro                                            Contract/Grant                             Andrea Martinez
                                                             Lyn Milliken
                                                                                         Administrator (0.5)
                                                                                                                     Award           Contract/Grant
                                 Proposal                                                 Loretta Negrete
                                                                                                                 Processor (1.0)    Administrator (1.0)
                                Analyst (1.0)
                                                                                                                 Meagan Taylor         Scott Bell
                                   TBD                                                    Contract/Grant
                                                                                         Administrator (0.5)                           Subcontract
                                                                                           Virginia Hart             Award            Administrator
                                                                                                                 Processor (1.0)          (1.0)
                                                                                                                      TBD             Mindy Vallejos




                                                                               10
     SPONSORED PROJECTS ACCOUNTING
          FINANCIAL OVERSIGHT
                         11


 MANAGE THE FINANCIAL ASPECTS OF AN AWARD
 AFTER IT IS RECEIVED.

 MAINTAIN SYSTEMS TO ENSURE COMPLIANCE
 WITH UNIVERSITY, STATE, FEDERAL, AND AGENCY
 RULES AND REGULATIONS.

 CONSULT/ADVISE/TRAIN/ASSIST WITH THE
 FINANCIAL ADMINISTRATION OF PROJECTS.

 PROVIDE GENERAL FINANCIAL ACCOUNTING FOR
 FUNDS 30 AND 31.
COST PRINCIPLES SHAPE THAT OVERSIGHT
                                   12

 Accounting Standards (aka, Generally Accepted Accounting
  Principles), defined and issued by the American Institute of Certified
  Public Accountants
 Financial Accounting Standards Board (FASB)

 Governmental Accounting Standards Board (GASB)

 Federal Cost Principles for Educational Institutions (OMB Circular
  A-21), including Cost Accounting Standards and Exceptions
 State of Colorado Fiscal Rules

 The University of Colorado, as your employer, sets its own policies
  and practices that we must follow
 Last, but not least, the sponsor may set specific conditions we must
  abide by in return for the money they are providing
Regulations, Policies & Procedures: Order of Precedence

                          13
              SPA RESPONSIBILITIES
                                  14
Customer Support
                                       Internal Compliance
 Set Up Projects and Load
                                        Cost Sharing
  Budgets into PeopleSoft
                                        Cost Transfers
 Provide speedtype information
                                        Effort Reporting
  to dept and OCG after
  PeopleSoft assigns the number
                                       Billing
 Maintain SPINS (Sponsored
                                        Invoicing
  Projects Information System)
                                        Cash Management
 Prepare Financial Reports
                                        Collection
 Monitor Expenditure Rates
 Provide Financial
  Oversight/Assistance
 Provide Liaison
 Provide Training
 Project Closeout
 Coordinate Audits
   DISTRIBUTION OF SPA FUNCTIONS
              (Who are you going to call? See Handouts)
                                  15

Speedtypes:                     Bev/Lori
Project Numbers:                Bev/Lori
Cost Share:                     Demetria
PO/SPO Req Approval:            Hua
JEs/Cost Transfers:             Jim Sheppard
Effort Reporting:               Hua
Billing &Payments Rec‟d:        Billing Tech
Agency Requirements:            Grant Accountant
Financial Reports:              Grant Accountant
Project Expenses:               Grant Accountant
Financial Closeouts:            Grant Accountant

                                  OR
               Diane Przygocki@colorado.edu (303-492-7213)
                Pat.Dodson@colorado.edu (303-492-2620)
               Sandra.Godden@colorado.edu (303-492-2614)
                               Organizational Chart
                         ABS Sponsored Projects Accounting
                                                          James Lei
                                                   Assistant Director, SPA


                                Diane Przygocki                                            Pat Dodson
                                                     Sandra Godden
                                Customer Service                                           Compliance,
                                                      Billing & A/R
                                                                                      Cost Transfers/Sharing


              Sutha Thanikasalam                                        Jeni Comly                        Demetria Ross



               Sharon DeCarlo                                         Sylvia Estrada                           Hua Xu




                 Mike Bussey                                            Pat Libhart                        Jim Sheppard




                  Terri Roark                                       Maribel Markham



               Lauren Caraballo                                       Charlotte Whyte



                  Bev Baran



Lori Haynes
                                                       16
                    FAQ
                       17



 Who is the grant accountant in charge of this
  project?
 How much money left in this project?
 Is that ok to charge XXXX to this project?
 What‟s the ST for this project?
 Why is my JE or PO Req stopped or hung up
  in SPA?
 I received a check from the sponsor, what
  should I do?
Financial Assistance Awards as defined by the
Federal Grant and Cooperative Agreement Act, 31
U.S.C. 6304 and 6305):

Grant or Cooperative Agreement:

•a legal instrument used by a Federal agency to enter into a
relationship whose principal purpose is assistance (that is, the
transfer of something of value to the recipient to carry out a
public purpose of support or stimulation authorized by U.S.
law).

•Grant is used when substantial involvement between the
recipient and the Government is not contemplated

•Cooperative agreement is used when substantial involvement
is contemplated.

                               18
Award as defined by OMB Circular A-110:

Financial assistance that provides support or stimulation
to accomplish a public purpose. Awards include grant and
other agreements in the form of money or property in lieu of
money, by the Federal Government to an eligible recipient.

The term does not include:
  • Technical assistance in the form of services and not money
  • Other assistance in the form of loans, loan guarantees,
       interest subsidies or insurance;
   • Direct payments of any kind to individuals;
  • Contracts which are required to entered into and
       administered under procurement laws and regulations.




                               19
“Contract” defined by the sponsor:

Federal contract means an acquisition contract awarded by an
agency, including those subject to the Federal Acquisition Regulation
(FAR), and any other acquisition contract for real or personal property
or services not subject to the FAR. (14 CFR 1271 - NASA); or

Contract - a mutually binding legal relationship obligating the
seller to furnish the supplies or services (including construction) and the
buyer to pay for them. It includes all types of commitments that
obligate the Government to an expenditure of appropriated
funds and that, except as otherwise authorized, are in writing. In
addition to bilateral instruments, contracts include (but are not limited
to) awards and notices of awards; job orders or task letters issued under
basic ordering agreements; letter contracts; orders, such as purchase
orders, under which the contract becomes effective by written
acceptance or performance; and bilateral contract modifications.
Contracts do not include grants and cooperative agreements
covered by 31 U.S.C.6301, et seq. For discussion of various types of
contracts, see Part 16. (FAR 2.101 (b)); or
                                    20
Contract – a procurement contract under an award or
subaward and a procurement subcontract under a recipient’s
or subrecipient’s contract. (OMB Circular A-110); or

Contract - “…a promise or a set of promises for the breach of
which the law gives a remedy, or the performance of which the
law in some way recognizes a duty.” (Restatement of Contracts,
2nd Addition; The American Law Institute Publishers, St. Paul,
Minnesota, 1981 – i.e. commercial/industrial); or

“A promise for a promise” (common person); or

An a agreement that the courts will enforce (attorneys); or

A well written agreement between the parties that answers who,
what, when, where, how, and, what to do if…(you and me…)

                              21
Subcontract / Subaward defined:

Subcontract - any contract as defined in Subpart 2.1 entered into by
a subcontractor to furnish supplies or services for performance of a
prime contract or a subcontract. It includes but is not limited to
purchase orders, and changes and modifications to purchase orders.
(FAR 44.101)


Subaward: an award of financial assistance in the form of money,
or property in lieu of money made under an award by a recipient to an
eligible subrecipient or by a subrecipient to a lower tier subrecipient.
The term includes financial assistance when provided by any
legal agreement, even if the agreement is called a contract,
but does not include procurement of goods and services nor
does it include any form of assistance which is excluded from the
definition of “award. (OMB Circular A-110)

                                  22
        Responsible Conduct of Research
                              23

Responsible Conduct of Research (RCR)
 Educational, training and mentoring program required by
  the COMPETES Act to promote high standards in conduct
  and intellectual honesty in support of NSF research awards.
 January 4, 2010 NSF will require UC Boulder to certify that
  we have a program in place to promote “responsible and
  ethical conduct of research to undergraduate students,
  graduate students and postdoctoral researchers
  participating in proposed research projects.”
 RCR Steering Committee was formed October 2
         Responsible Conduct of Research
                                     24

 Very complementary to other ethics and integrity initiatives
  affecting the University:
      Public Health Service and NIH – May 2009 Federal Register
       Advance Notice of Rulemaking, NIH 2008-0002, Update on
       regulations for promoting objectivity in research.
      FAR Contractor Code of Business Ethics and Conduct (52.203-13)


 Promote and Identify Shared Values*
     Honesty – conveying information truthfully and honoring
      commitments
     Accuracy – reporting findings precisely and taking are to avoid
      errors.
     Efficiency – using resources wisely and avoiding waste
     Objectivity – letting the facts spear for themselves and avoiding
      improper bias
                                * Source;:DHHS Introduction to Responsible Conduct of Research
              Kinds of Proposals
                          25



 New = first submission or a revision to a first
  submission
 Continuation = non-competing continuation of an
  active project
 Renewal = competing continuation of an active
  project
 Supplement = addition to an active project (treated
  essentially as a new proposal)
       WHAT OCG NEEDS
                       26


PROPOSAL INFORMATION:
 PI/Co-PIs
 Departments
 DA/ICR Split
 Sponsoring Agency
 RFA/RFP/Program Announcement
 Is cost share required?
 Deadline
           COMPLIANCE ISSUES
                              27
 Human Subjects
     Melissa Diemer ,Graduate School (735-3702)
   Animal Care and Use
     Silvia Iorio, Graduate School (492-8187)
   Bio-Safety/RDNA
     Denise Donnelly, EH&S (492-7072)
   Radiation Safety
     Michelle Law, EH&S (492-6523)
   Conflict of Interest/Financial Disclosure
     Jean Wylie, Graduate School (492-3024)
   Cost Sharing/F&A Waivers
     Russ Moore, Graduate School (492-1087)
   Import/Export Issues
     Linda Morris, Graduate School (492-2889)
        WHAT OCG NEEDS
                        28


            BUDGET INFORMATION:

 Start and end dates
 Project Title
 Names of PI and all Co-PIs
 Personnel and their level of effort
 Equipment
 Travel
 Other Direct Costs
 Cost share expenses, if part of the proposal
                                               OCG Budget
                                                                  29
CU Proposal No.

                                  PROPOSED BUDGET DETAILS

Institution:   The Regents of the                 Title:     Microsensors for Motion Detection
               University of Colorado                        in Southern African Animal Habitats
               572 UCB
               Boulder, Colorado 80309-0572


Principal Investigator: Elizabeth Bennet          Duration: 6-1-10 - 5-31-11

A. Salaries and Wages                                                                        Other types of UCB personnel:
   Principal Investigator: Elizabeth Bennet                                                  Research Associate
      100% time, 1 mo Summer                                      13,224                     Professional Research Assistant
   Graduate Research Assistant: to be named                                                  Technician
      50% time, 9 mos AY                                          15,529                     Program Assistant
                                                                                             Accounting tech
       Total Salaries and Wages                                   28,752
                                               OCG Budget
                                                   30

B. Fringe Benefits
   PI: 24.4%                                            3,227   Federally negotiated
   GRA: 5.3%                                              823   Rate Agreement: changes every year

   Total Fringe Benefits                                4,050

C. Permanent Equipment
   Laptop computer for field work
     with software and printer                          5,000   $5,000 or greater with a useful life
                                                                of one year

D. Travel, Foreign
   Airfare: $1,200; Per diem: $100, 30 days;
   Ground transportation: $500                          4,700   Field work travel

   Total Travel                                         4,700
                                                    OCG Budget
                                                        31
E. Other Direct Costs
   Supplies: sensors, wires, chips                              5,000
   Shipping                                                       300
   Subcontract: University of Florida                          25,000   Sole source justification form
   Subcontract: University of Cape Town                        75,000
   Tuition remission, Resident                                 11,353

   Total Other Direct Costs                                   116,653

F. Total Direct Costs                                         159,155

G. Indirect Costs
   On campus: 51.5% of MTDC, predetermined for
   the period 7/1/06-6/30/10, provisional thereafter.
   Per HHS agreement dated 3/30/09.                            47,793

H..Total Costs                                               206,948
WHEN AN AWARD IS RECEIVED…
                         32


 award details are entered in Filemaker Award
  Database by Award Processor
 award is reviewed and negotiated by CGA

 if necessary, award is signed by Director

 if new award, SPA assigns project number and
  speedtype is generated
 email notification sent to PI and Department
  Administrator detailing project number,
  speedtype; copy of award and budget are
  attached
        COMMON DELAYS
                      33




 revised budget needed

 proposal not submitted through OCG

 unacceptable language and terms in contract

 no human/animal subject approval

 award received unexecuted
   PRE-AWARD AUTHORIZATION
                         34




 Federally funded Grants may include automatic
 authorization to spend grant funds up to 90 days prior
 to the official start date of the grant.

 Pre-award spending on Contracts requires explicit
 authorization from the sponsor‟s Contracting Officer.
PRE-AWARD SPENDING ACCOUNTS
                          35


 Submit an OPAS form (grants) or At-Risk Project
  form (contracts) to your CGA for consideration of a
  pre-award spending account.
 In order to set up a pre-award spending account, we
  must have information that the award is forthcoming
  and know the effective start date.
 Departments are financially responsible for any
  project costs that are disallowed if an award is not
  issued/executed or if the expenses are incurred prior
  to the estimated 90-day pre-award period. A
  department guarantee signature is required on the At-
  Risk form and may be required on the OPAS form.
MANAGING THE AWARD
               36




 Travel
 Equipment
 Budget Deviations/Revisions
 Changes in scope/tasks
 No Cost Extensions
 Subcontracting
             REVISED BUDGET vs.
          BUDGET DEVIATION (OPAS)
                                  37


 Only the sponsor can establish the “approved budget.” Thus, only
  the sponsor can approve “rebudgeting.”
 Most awards allow for “budget deviations.” In some cases, budget
  deviation requires internal OCG approval (for example, for
  unbudgeted equipment items).
 Rebudgeting approval from the sponsor results in changes to the
  budget in the financial system. Budget deviations approved by OCG
  do not result in changes to the budget in the financial system but
  are noted in Filemaker in the remarks field.
 It is important that the original budget, as approved by the sponsor,
  remains intact in the University‟s financial system in order for
  actual expenditures to be accurately compared with the approved
  budget.
    SPONSOR APPROVAL REQUIRED
                           38


The terms and conditions of most federal financial
assistance awards allow for flexibility in spending
except for the following limitations:
 transfer of the project effort to another organization
 change in objectives or scope
 change in PI
 a substantial change in PI effort (usually defined as
  25% or more)
 reduction in a cost sharing amount identified in the
  award budget
 reallocation of funds budgeted for “participant
  support”
 construction activities costing $25,000 or more
          NO COST EXTENSIONS
                          39


Include the following information in your request:
   desired end date
   brief summary of the progress to date
   brief summary of the work to be accomplished
   estimate of remaining funds
   brief description or informal budget detailing how
    the remaining funds will be spent

 All no-cost extensions requests require genuine
  programmatic justification. Sponsors do not permit
  no-cost extensions solely for the purpose of spending
  the remaining funds.
     5 Criteria To Define a Subrecipient
                              40

1. Funds are being paid to a university or non-profit entity
   (occasionally to a for-profit business) rather than to an
   individual.
2. Subrecipient is acting as a collaborator and contributing
   to the scientific/scholarly conduct of the project.
3. Subrecipient portion of the project requires use of
   discretion and unique expertise available from only one
   source.
4. Subrecipient does not provide similar services to others
   as their primary business.
5. Has its performance measured against whether the
   objectives of the Federal program are met.
Establishing a Subaward at the Proposal Stage
                                   41

           INPUT REQUIRED FROM PRINCIPAL INVESTIGATOR

   Contact Name and address of Subrecipients‟s grants/contracts
      office.
     Specific Statement of Work with deliverables.
     Period of performance.
     Subrecipient key personnel.
     Detailed Budget and Budget Justification
     Subrecipient‟s most current federally negotiated rate agreement
     The signature of an authorized official of the Subrecipient,
      signifying the collaborator‟s commitment to carrying out the
      project if funded.
     Explanation of how and why the Subrecipient was selected. (Sole
      Source Justification)
     Confirmation of whether or not a Conflict of Interest exists.
            Administering Subawards
              at the Award Stage
                         42




 Principal Investigator will approve the Subaward
  before it is issued.
 A reduction in Prime Award funding may require a
  revised Budget and Sow from the Subrecipient.
 Payments should be made only after an invoice is
  approved by Principal Investigator.
 Contact OCG with problems or to modify a
  Subaward.
                Things to Remember
                               43


 Principal Investigator needs a Subaward issued immediately.


 Information required by OCG to issue a Subaward to the
  Subrecipient is furnished by the Principal Investigator.
  Please furnish complete information to avoid delays.

 University F&A apply only to the first $25,000.

 PI should always be in close contact with the Subrecipient to
  monitor their ongoing progress.

 If the departmental administrator is not receiving Subrecipient
  invoices, something is wrong - investigate!
        44




FINANCIAL OVERSIGHT
OF SPONSORED AWARDS
INTRODUCTION TO OMB CIRCULAR A-21
                           45


 DEFINES "ALLOWABLE COST“

 INSTRUCTIONS FOR THE UNIVERSITY TO ALLOCATE
 INDIRECT COSTS PROPERLY AND TO CALCULATE THE
 INDIRECT COST RATE

 APPLIES TO PROJECT COSTS REIMBURSED BY THE
 GOVERNMENT AND TO COST SHARING OR MATCHING FUNDS

 TESTS OF ALLOWABILITY:
    ALLOCABLE TO (BENEFITS) THE PROJECT SUPPORTED BY
     THE GRANT OR CONTRACT
    REASONABLE
    TREATED CONSISTENTLY AS EITHER A DIRECT OR
     INDIRECT COST
      UNALLOWABLE COSTS (cont‟d)
                             46




 See Handout for list of unallowable charges
 Food/Meals
    Allowed as part of travel, conferences, or business
     meetings with external participants
    NOT allowed for staff meetings, pizza in the labs,
     working meals with project employees, general
     refreshments, i.e. donuts, coffee, bottled water
     Except  as approved by sponsor or
       within scope of work
ALLOWABLE AND UNALLOWABLE COSTS
                                 47




 Remember the last of the tests for allowability:
     ALL COSTS MUST BE TREATED CONSISTENTLY
      IN LIKE CIRCUMSTANCES
     That is – like costs should be treated the same
         Costs normally direct should be treated as direct

         Costs normally indirect should be treated as indirect,
          even in sponsored projects
       DIRECT vs INDIRECT COSTS
                             48




 What are direct costs?

    Identified specifically with a particular sponsored
     agreement and “Incurred solely to advance the work
     under the sponsored agreement”

    Assigned to a sponsored agreement relatively easily and
     with a high degree of accuracy
       DIRECT vs INDIRECT COSTS
                                49


 What are Indirect Costs?
   Support common or joint activities


     Benefit numerous projects
       Cannot readily be identified with a particular sponsored
        project
       Cannot be proportioned to benefit a group of sponsored
        projects with relative ease or with a high degree of
        accuracy

     Known as F&A costs (Facilities & Administrative) at UCB

 Handout
                    Direct Cost Policy
                                 50


 Per OMB A-21 and the UCB Direct Cost Policy, the following
 three criteria must be met for F&A costs (Indirect) to be
 directly charged:
 1.   The costs must be specifically and readily identifiable to a
      specific project with a high degree of accuracy.
 2.   The costs are required by the project scope, due to the
      project‟s special purpose or circumstances.
 3.   The costs must be specifically budgeted as a line item in
      the proposal budget, justified in the proposal narrative,
      approved by OCG, and authorized by the funding agency.
 *Handout
             OMB CIRCULAR A-110
                            51



 Issued by the Office of Management and
  Budget
 Issued to Federal agencies, not to sponsored
  institutions
 Requires that institutions will have in place
  policies, procedures, and management systems
  adequate for monitoring sponsored project
  performance

 http://www.whitehouse.gov/omb/circulars/a110/a110.html
 now 2 CFR 215
  AUDITS and
OMB Circular A-133
              52



  STANDARDS FOR OBTAINING
 CONSISTENCY AND UNIFORMITY
FOR THE AUDIT OF STATES, LOCAL
GOVERNMENTS, AND NON-PROFIT
  ORGANIZATIONS EXPENDING
      FEDERAL AWARDS.
                  Audits
            OMB CIRCULAR A-133
                             53



Audits are tools sponsors use to ensure
we are being good managers
   Audits review large number of items/issues,
    including (but not limited to):
       charging unallowable costs to projects
       the timing of charges
       check -- Do we follow our own policies and
        procedures?
       ensure we are meeting our obligations as committed
        in our proposals
              OMB CIRCULAR A-133
                                  54


 What they are looking for:
     Direct attribution must be established and demonstrated
      through supporting documentation
     Readily identifiable causal-beneficial relationship must exist
      between costs and the project
     Costs incurred for the same purpose in like circumstances
      should be treated consistently as either direct or indirect
     Indirect costs in award budget must have sufficient
      justification of different purpose and circumstance
     Other testing includes effort reporting, cost transfers, program
      income, reporting, sub-contract monitoring, etc…
              FINANCIAL COMPLIANCE
                                        55

There are certain types of expenses and obligations that get extra
scrutiny by federal sponsors & auditors.
SPA has created procedures to provide additional oversight to
these “special” categories
Three Topics in Particular:
      “After the Fact” cost transfers [aka, Journal Entries (JEs), Payroll
       Expense Transfers (PETs)]
      Sharing project-related expenses with the sponsor [aka, Cost Sharing]
      Certifying work effort has been devoted to sponsored projects [aka,
       Effort Reporting]
UCB Policies have been created for each of these and there are specific
procedures associated with them
             JEs / COST TRANSFERS
                                   56


Journal entries reassign costs to a sponsored project
after they were initially charged to another account
        Can use cost transfers to correct errors
        Can move over-expenditures to a non-restricted source
         of funding (i.e., dept account)
        Cannot use JEs to expense out unspent funds
        Cannot move overdraft expenses to another sponsored
         project just to clear the deficit

Just because transfers are OK, they must still meet
specific procedural requirements
     JEs / COST TRANSFERS (cont‟d)
                                  57
Justification:
 According to federal guidelines, "an explanation which merely
  states that the transfer was made 'to correct error' or 'to transfer
  to correct project' is not sufficient.“
   why was correct account not charged initially;
   how does this expense benefit the project receiving it; and
   if more than 90 days from initial entry, why did it take so long
     to do.
Documentation:
 SPA needs documentation on specific types of expenses before
  we can approve      (see handout)
Format:
 Each journal must transfer specific individual transactions, and
  must also identify the original transaction Journal ID number
  and original Journal Date. Lump-sum cost transfers are usually
  not permitted. (see handout)
       JEs / COST TRANSFERS (cont‟d)
                                 58



    SPA CANNOT APPROVE A JE UNTIL
         IT HAS DEPARTMENTAL
               APPROVAL
   Creator needs to contact approver and then follow up when not
    approved

   PETs need only SPA approval when involving Fund 30 or 31

Policy:
  http://abs.colorado.edu/ABS_WEB/policies/costtransfer.pdf
                COST SHARING
                            59



Sometimes University formally commits to pay for a
certain portion of a project‟s costs.

  Once we have COMMITTED Cost Share at the proposal
  stage, we are obligated to ensure we have fulfilled the
  commitment, whether or not the sponsor asks
  for a report



Policy:
http://abs.colorado.edu/ABS_WEB/policies/costshare.pdf
                  COST SHARING (cont‟d)
                                       60

Cost sharing with cash contributions
         Record cash and associated expenses in separate financial
          account (FOPPS)
          SPA will request setup from Accounting --- C/S contributions and
           expenses should be allocated to that FOPPS
         C/S expenses can‟t be used twice
         Allowable under award or contract terms
         Incurred within period of performance (POP)

Cost sharing with non-cash contributions
         Work effort paid with University funds but devoted to
          sponsored project
          OR
         Donations or contributions of services or materials that do
          not require cash outlay by the University
         Both require certification from providers
            COST SHARING (cont‟d)
                                 61


NOTE:
The tracking, reporting, and certifying of cost sharing
are subject to audit. Therefore, records for all cost
sharing commitments are to be retained for the same
period as the records for its related sponsored
agreement.

Sometimes University contributions to a project were
unplanned
      Known as “incidental” --- doesn‟t need tracking
      PI can report that in progress reports but isn‟t quantified
       by SPA
      This isn‟t subject to audit
                 EFFORT REPORTING
                                     62


Federal Mandate = if federal dollars pay for salary
expense in sponsored projects, we must have a
system creating reports that “reasonably reflect”
employee activities to verify work on those projects
     referred to as “effort reporting”
     effort is recorded via the electronic personnel effort
      reporting system (ePERs)
     12-month period is divided into 3 units for reporting
      purposes
            After each semester (early June, early Sept, early Jan)
     ePER should reflect where effort was spent THAT semester
     EFFORT REPORTING (cont‟d)
                              63


Policy:
http://abs.colorado.edu/ABS_WEB/policies/epers.pdf

Internal Audit is completing their report of review of
University‟s ePER system and may have some
recommendations


Federal auditors are closely scrutinizing this
compliance area, particularly for summer
months of AY faculty
          Invoicing Basics
                       64




 We start invoicing after month end close,
 usually the 4th -7th of the month.

 Make sure all expenses are posted to the
 correct project by month end.
               Invoicing Basics
                             65


   Depending on the Sponsor and contract we may be
    asking for:
     Travel Documentation
     Copies of receipts for Fixed Assets and Operating
      Expenses
     Copies of Subcontract invoices, sometimes with backup
     Reports
     Breakdown of salaries by name, hours worked, hourly
      rate
     and anything the Sponsor requests so they will pay the
      invoice.
            Invoicing Basics
                        66




 The „I have 90 days after the end date to get my
 act together' Myth

 SPA needs to invoice within 90 days-so you
 have 60 days to make changes and get expenses
 where they belong
                  Invoicing Basics
                                 67




 EXCEPTIONS:
   Projects that require Final Invoices 30, 45, or 60 days
    after the end date

     Billing Techs send an email at the beginning of the
      project and before the end date to the PI and DA to let
      you know that all expenses must be posted by the end
      date.
        Sponsor Reimbursement
                           68




 Sponsored Projects can receive funding in
 several ways:
    Check with the Award, not very common
    Cost Reimbursable-the University is reimbursed by the
     sponsor for actual costs incurred
    Scheduled Payments
       Sponsor Reimbursements
                          69



 Cash is managed by Sponsored Project
 Accounting.
  If you receive a check that you think may be related
   to a Sponsored Project, please send it to SPA
   574UCB, Attn: Maribel. Include the project number
   if it is not on the check.
  Maribel will post it to your project.

  Questions to Sandra 303-492-2614

  Sandra.Godden@colorado.edu
        Invoicing Basics
                  70




  If you do not have the time to do it
right the first time, when do you think
    you will have time to do it over?
Sponsored Projects Close out
        Procedures
             71
      CLOSE-OUT PROCEDURES
                              72

Unless the awarding agency authorizes an
extension, a recipient shall liquidate all obligations
incurred under the award not later than 90
calendar days after the funding period of the date of
completion.
    Recipients shall submit, within 90 calendar days after
     the date of completion of the award, all reports as
     required by the terms and conditions of the award:
        Technical
        Financial
        Property
        Patent
    Equipment disposal requests must be submitted to OCG
           Responsibility of SPA
                             73



 Most final financial reports are due to the
 agency on or before 90 days after the project
 end date.
    For Your Grant Accountant to report timely and
     accurately, your transactions must be completed
     within 60 days after the end of the project:

      Resolve over-expenditures
      Remove unallowable expenses
      Correct accounting errors –JE‟s and PET‟s




                                                       73
                 CONSEQUENCES
                              74


Delinquent reports of any kind can result in:
   Sponsor withholding new or continuing awards to a
    particular principal investigator or possibly the entire
    campus.
   The funding agency can withhold payment to the University
    of amounts owed; also, extreme cases of delinquent reports
    could result in the funding agency demanding the return of
    amounts already paid.
   Exposure to audit findings and disallowances
   Cash management issues
              Project Review
                       75



 Importance of Monthly Review (easier to
  catch early, limit cost transfers, aka JE‟s)
 Many overdrafts due to salary
 Subcontracts greater than $25,000
 Unallowables
 Budget deviations
 Rate of spending (under or over)
 DOCUMENT, DOCUMENT, DOCUMENT
               CLOSE-OUT-cont‟d
                             76


 SPA sends notifications of projects ending
 within the next 2 months
    Review projects to determine that
      Expenses are accurate and allowable
      Encumbrances are legitimate and will be liquidated in a
       timely manner
      Standing Purchase Orders have been terminated, or
       FOPP has been revised
      Cost-sharing obligations have been met and documented
      HR procedures have been followed to change and/or end
       appointments
      *Handout
             CLOSE-OUT-cont‟d
                           77




 If an award has ended and the project is in
 deficit, the Grant accountant will notify the
 Department Administrator that the deficit will
 need to be removed so the correct expenses can
 be reported to the agency.

 If no action is taken…
            The Procedure
                       78




“It is Boulder Campus policy to turn to a unit‟s
    other accounts for funds to cover any such
         overdrafts that are not resolved.”
             The Procedure cont‟d
                          79




 First Notice: The designated key contact and PI
  will be advised by email of specific items of
  concern
 Second Notice: If problems have not been resolved
  within 30 days of the first notice, the department
  chair, the designated key contact and the PI will be
  advised by email


                                                    79
             The Procedure cont‟d
                         80




 Final Notice: Over-expenditures, unallowable
 expenses, or undocumented cost transfers will be
 charged to the Departmental Administration Indirect
 Cost Recovery (DA-ICR) FOPPS, if issues have not
 been resolved after 30 days from the date of the
 Second Notice.



                                                 80
                     FAQ
                       81



 Who is the grant accountant in charge of this
  project?
 How much money left in this project?
 Is it ok to charge XXXX to this project?
 What‟s the ST for this project?
 Why is my JE or PO Req stopped or hung up
  in SPA?
 I received a check from the sponsor, what
  should I do?
                   RESOURCES
                            82



   Vice Chancellor of Research web site
  http://ucw.colorado.edu/VCResearch/index.html
                    OCG web site
              http://www.colorado.edu/ocg
 Accounting & Budgeting Services web site
                  http://abs.colorado.edu
    Office of Management and Budget
          http://www.whitehouse.gov/omb/
     83




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DOCUMENT INFO
Description: Cost Sharing Interest Agreement document sample