Contract and Grant Regulatory and Compliance Workshop

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Contract and Grant Regulatory and Compliance Workshop Powered By Docstoc
					Post Award Administration
of Sponsored Projects
Presented by:

    The Office of Research &
     Sponsored Programs

                and

       Grants Accounting

                               2
Today’s Topics
 Financial:
    Grants Accounting Office
    Principal Investigator (PI) Responsibilities
    Expenditures
    Cost Transfers
    Time & Effort Reporting

 Program:
    No-Cost Extensions/Continuations
    Subcontracts
    Progress Reports
    Close Out
                                                    3
    Grants Accounting Office
   Resource for Award Recipients
      Clarification on terms & conditions
      Assist with award management, BANNER, etc.
      Financial Status Updates


   Services for Award Recipients
      Invoicing and collections
      Financial reporting
      Track cost share


   Compliance / Audit Assurance
      Code of Federal Regulations (2 CFR 220/OMB Circular A-21)
      Audits & Reviews
      Monitor expenditures charged
      Evaluate cost transfers
      Collect documentation
                                                                   4
5
Financial Status Updates
 Advantages
      Shows estimated available balance by budget category
      Shows encumbrances BANNER does not
         Salaries for PAF‟s that extend beyond the end of the

          current fiscal year
         Benefits and F&A cost recovery



 Limitation
      Only includes expenses Grants Accounting knows about
         P-Card charges and chargebacks post after the last day

          of the month
                                          th
         P-Card charges made after the 26 of the month post on

          the following cycle
                                                                   6
  PI Responsibilities

 The PI has the primary responsibility to:
   Financially
      Manage the award with care and diligence
      Know and adhere to all terms and conditions
      Ensure that expenditures charged to the award
       are appropriate
      Document appropriateness of expenditures in
       accordance with sponsor regulations and University
       practices
      Initiate PAF‟s for personnel working on the project
      Review expenditures posted to the award index on a regular
       basis (recommend monthly review)                             7
  PI Responsibilities

 The PI has the primary responsibility to:
   Programmatically
      Achieve technical objectives of the project
      Execute the project as outlined in the funded proposal
      Monitor and ensure the integrity of any collaborative
       relationships
      Complete all applicable technical reports in an accurate and
       timely manner (progress/interim/final reports, patent/invention)
      Comply with all applicable rules, regulations and terms and
       conditions of the award, including those of the University


                                                                          8
  How to Review Expenditures

 Open Lab for Budget Questions
     Hands on, personalized assistance
     BANNER Self-Service or Internet Native BANNER
     Usually 2nd Monday of the month
     Contact: Angela Catlos X6728

 BANNER Self-Service
     Reports by fiscal year
     Reference guide on DOCS under
      „Budget & Business Services‟
     Abbreviated version available from
      Grants Accounting

                                                      9
  How to Review Expenditures

 Internet Native BANNER

      Separate channel on DOCS
      Reporting options more flexible
         Multiple fiscal years, across fiscal years, specific month

         Run detail report or summarize by budget category


      View expenditures: use FRIGITD screen
         Only need to fill in 2 fields and click on „Next Block‟ icon

         Quick Reference Guide available


      Export expenditures to Excel: use FRIGTRD screen
         Quick Reference Guide available


                                                                         10
  How to Review Expenditures

 Limitation of either instance of BANNER
      Only includes expenses that have been processed and
       posted in Accounting
         P-Card charges and chargebacks post after the last day

          of the month
                                           th
         P-Card charges made after the 26 of the month post on

          the following cycle

      Does not encumber:
         Salaries past the end of the fiscal year or most recent

          PAF, whichever is earlier
         Benefits

         F&A Cost Recovery

                                                                    11
    General Statements About Expenditures

   Statements made regarding the
    allowability of or limitations on specific
    types of expenditures reflect what is
    generally true of most grants
   Actual terms and conditions vary from
    one grant to another

   Always review the Notice of Grant Award
    to determine the specific terms and
    conditions that are relevant to each
    individual award

                                                 12
Expenditures


What does Grants Accounting look
 for when monitoring expenditures?

 Would you like to know
 how your expenditures
 can FLY through the
 review process?
                                     13
  Expenditures

 Prepare expenditures to FLY on the:

    Timing
    Allowability
    Reasonableness
    Money
    Allocable
    Consistent

                                        14
   Expenditures

 Timing: Grant Budget Period
      Expense must be incurred within the authorized period
      Pre-award costs may be permitted

 Allowability
      Award Terms and Conditions
      Sponsor Policy/Guidelines
         Federal Government: 2 CFR 220/A-21

         Federal Agencies: DHHS Policy, NIH Policy, NSF Policy, etc.

         State Agencies: ODMH Guidance, OCJS Guidance, etc.

         Private Entities: AHA Guide for Grant Awardees, etc.

      University Policy/Practices
         Purchasing Policy, Travel Guidelines, etc.                15
  Expenditures

 Reasonableness
     Prudent person would agree that expenditure was necessary
      for the project and that the price was appropriate
     Prudent person would agree that expenditure was made at a
      time that it could be reasonably expected to benefit the project
          Example: equipment – within 90 days of the end of the project?
          Example: supplies – within 30 days of the end of the project?


 M oney
     Available funds in budget category
     Re-budgeting may require sponsor‟s prior approval
     Grant Budget Reallocation Form
                                                                            16
   Expenditures

 Allocable
      Charge award in accordance with amount of benefit
      If incurred solely to advance one project: charge 100%
      If incurred to advance multiple projects: charge each project
       proportionally in accordance with the benefit received
      Can be difficult when multiple projects are funded
          Must use a „reasonable basis‟ for allocation

               Determined by individual circumstances
               Examples: # of experiments, % of effort, reasonable
                estimate of use, etc
               Cannot be based on the amount of funds available

                                                                       17
   Expenditures

 Consistent Treatment
      Direct vs. Indirect Cost
             Examples of indirect: lab space, electricity, support staff,
                                    general use computers

      Cannot charge award for an expense that would NOT be
       applied to non-sponsored program index
             Example: service contracts for equipment
             “Most Favorite Customer” rule




                                                                             18
   Expenditures of Special Interest
 General Purpose Equipment
      Equipment not limited to research, scientific or other technical activities
      Examples: office equipment and furnishings, telephones, information
       technology equipment, printing equipment, etc.
      University policy: $2,500 or more AND useful life of at least one year
      Unallowable as direct charges except where approved in advance by the
       awarding agency

 Special Purpose Equipment
      Equipment limited to research, scientific or other technical activities
      University policy: $2,500 or more AND useful life of at least one year
      Exception to the allocation cost principle
      University-wide equipment search required if using Federal funds

                                                                                 19
  Expenditures of Special Interest
 Office Supplies
      Typically included in F&A
      Often unallowable as a direct cost
      Exception may be available if all of the following apply:
         Project requires office supplies above and beyond normal use levels

         Office supplies are necessary to conduct the substance of the project

         The purchase is reasonable, allocable and allowable




 Meals
      Allowability varies
      Where it is allowable, often only available when on travel status



                                                                           20
  Expenditures of Special Interest
 Travel
      Airfare in excess of lowest available rate is unallowable
         Exceptions usually available if it would result in traveling at

           unreasonable hours, would excessively prolong the duration
           of travel, etc.
      International travel
          Often requires prior approval from sponsor

          Federal funds: Fly America Act


      Available on DOCS:
         Employee Expense Reimbursement Form

         Per Diem rates

         University Travel Guidelines
                                                                       21
 Expenditures of Special Interest
 Payments to Subcontractors

      PI must initiate subcontract with ORSP
      Subcontractor required to submit an invoice for payment

      The invoice should be detailed enough for the PI to
       determine that all charges are allowable to the grant
      The PI reviews the invoice and approves it only if the
       subcontractor has met the agreed to performance and
       reporting requirements



                                                                 22
Subcontracts
If included in proposal, email Beth Cline (ecline@neoucom.edu) with
     request for subcontract

 Provide the following information:
       Name and contact information of subcontractor (institution)
       Subcontractor key personnel
       Subcontractor scope of work
       Period of performance
       Dollar amount (special payment terms, if applicable)
       Reporting requirements
       Other special terms and conditions

If subcontract not included in proposal, sponsor approval required
 Charging Expenses to a Grant Index

 P-Card
     Reconcile by the 1st business day of the following month
        Can split charges among multiple indexes

        Manual / Pointers on DOCS



 Purchase Order
     Required for equipment, animals and chemicals
     Department enters requisition in BANNER
     Electronically sent to multiple reviewers for approval
          List of reviewers is based on type of purchase
     Equipment search required for purchases with Federal funds
     Accounting creates a purchase order and either places the order
      or notifies the department to place the order
                                                                   24
      Charging Expenses to a Grant Index

 Invoices
     PI or their designee must review and approve invoices for payment
          Supervisory Signatory Form

     Send invoices to Grants Accounting Office with:
        Signature

        Date of approval

        Index(es) and account(s) to be charged

        If splitting expense among multiple indexes include the dollar

         amount to be charged to each index
     Signature is confirmation that the expense is appropriate for
      payment from the grant index

                                                                      25
Cost Transfers
 What is a cost transfer?
      A cost transfer is the process of taking an expense off of the
       index it was originally charged to and moving it onto another
       index

 Why might a cost transfer be needed?
      Timing issue - pre-award costs/delay in obtaining index #
      Cost overrun or unallowable expense
      Clerical error

 How is a cost transfer initiated?
      Interdepartmental Charge & Cost Transfer Form

                                                                    26
    Cost Transfers
   Potential Audit Finding
       Auditors look for both volume and documentation of appropriateness

       Burden of proof is with University to prove transfer was appropriate

       Often interpreted as an indication of inadequate internal controls
          Casts doubt on the effectiveness of the University‟s processes
           to accurately administer awarded funds
          If processed past 90 days, casts doubt on the effectiveness
           of the University‟s processes to detect and correct errors

       Cost transfers between two sponsored programs are more likely
        to be challenged by an auditor

                                                                          27
Cost Transfer Documentation
   Timing Issues: Pre-award Costs/Index Delays
        Documentation should include:
           Brief explanation of the situation
               Indicate pre-award costs or cause of delay
               Additional documentation will be needed if the cost
                transfer is requested more than 90 days after the
                index for the new award is set up
        Existing awards cannot be used as a „holding place‟ for
         charges until a new award is set up
            Use departmental or designated index



                                                                      28
    Cost Transfer Documentation
   Cost Overruns or unallowable expenses
        Documentation should include:
            Brief explanation of the situation
                Indicate award is ending or expense disallowed
        Expenses moved to correct cost overruns
         or to move unallowable expenses must be
         charged to a departmental or designated index
         rather than to another sponsored project




                                                                  29
Cost Transfer Documentation
   Error correction - typos, miscommunications, etc.
       Cost transfer requires specific documentation
          Based on NIH Policy
          University practice requires same documentation for all awards
              Provides University with an argument if an auditor questions it
              Documents University‟s effort to improve internal processes and to
               reduce the need for future cost transfers

       Documentation should include:
          Brief explanation of how the expense was charged to an incorrect index
          Affirmative statement that the expense is appropriate for the index it is
           being moved to
          Brief explanation of the steps taken to avoid similar errors in the future
          If past 90 days: explanation of why the error was not detected earlier


                                                                                   30
 Cost Transfer Documentation
 Personnel expenses
     Requested via retroactive PAF
     Documentation is:
        Time & Effort Report

            Cost transfers that contradict the % of effort reported will
             require specific and compelling documentation
            Auditors and sponsoring agencies typically disallow
             re-certifications of effort
          Additional documentation may be requested in some
           circumstances
              Sudden increase in effort
              Near end of grant budget period
                                                                       31
   Time & Effort Certifications

 A Time and Effort Report is an after-the-fact confirmation of how an
   employee spent their time over the prior quarter
     Provides audit backup for personnel charges on grant index
     If obligated time as cost share: documents that cost share
      obligation has been met
     If obligated to spend specific % of effort on project: documents
      that % of effort obligation has been met

 Required by:
    Federal Government (2 CFR 220/OMB Circular A-21)
    Some state agencies


 Kept on record for 10 years and is subject to audit


                                                                     32
  Effort Certification Process
 At the end of each quarter Grants Accounting sends out Reports
   with an estimate of the employee‟s effort distribution
     Estimate is based on payroll records and cost share information
       received from ORSP or from the PI

 Percentages reflect 100% of employee‟s time regardless of the
   quantity of hours worked

 Confirm or correct the estimate via the „Actual Effort‟ column

 Must be signed by employee and a supervisor with first hand
   knowledge of how the employee has been spending his or her time
 Return Report to Grants Accounting with both signatures
       Grants Accounting will review any changes and contact the
        supervisor if a revised PAF is needed                       33
Progress Reports
 As required by the sponsor (see terms and conditions
  of award) – usually quarterly or annually
 Responsibility of the PI

 NIH: eSNAP. Prepared by PI, formally submitted by
  ORSP (Beth)
Close-Out
Why?
 To ensure adherence to sponsor terms and conditions
 Final review and approval of expenditures

 Programmatic
     Final technical/narrative report (e.g., eSNAP; requirements/timing
      depend on sponsor)
    Other, e.g.,
         Final invention statement and certification

         Disposition of equipment

         Reprints of articles

 Financial
    PI: final review of expenditures
    Grants Accounting: prepares/submits final financial report
 Additional Resources
 DOCS Channels
      Administration & Finance Forms & Resources
      Information for NEOUCOM/NEOUCOP Researchers

 ORSP Website
      http://www.neoucom.edu/audience/research/offices_programs
       /research_programs

 DHHS Website
      Grants Policies, Laws, and Regulations or
      http://www.hhs.gov/asrt/og/aboutog/grantsnet.html
          DHHS Grants Policy Statement

          NIH Grant Policy Statement

          Laws & Regulations - relevant CFR links

          Other Policy Resources - relevant OMB Circulars


                                                                   36
 Additional Resources

 NSF Grants Policy Statement
   NSF Grant Policy Manual


 Code of Federal Regulations/OMB Circulars
    2 CFR 220 (formerly OMB Circular A-21)
    2 CFR 215 (formerly OMB Circular A-110)


 Federal Audit Standard
    OMB Circular A-133




                                               37
Developments & Feedback Request

 Development of Online Resources
    pre and post award information
    general information, FAQs, forms and contacts

 Faculty and staff reviewers needed
    If interested, contact:

              Susan To, Grants Accountant
              X6380 or sto@neoucom.edu




                                                     38
  Summary
 Make use of the resources that are available.

 Be familiar with the PI‟s responsibilities pertaining to award
   administration.
 Keep track of PAF end dates; allow sufficient time for PAF‟s to be
   processed.
 Understand what makes an expenditure FLY through the review
   process (TARMAC).
 Review charges to your award on a regular basis. If there are
   questionable charges, resolve them as soon as possible.
 Please call, e-mail or come visit us if you have any questions!




                                                                       39
How to Contact Us
 Grants Accounting
   Susan To, Grants Accountant
           X6380 or sto@neoucom.edu
      Maureen Brown, Grants Specialist
           X6382 or mbrown@neoucom.edu


 The Office of Research and Sponsored Programs
    Beth Cline, Director
           X6498 or ecline@neoucom.edu
      Diana Dubinsky, Research Coordinator II
           X6497 or ddubinsk@neoucom.edu

                                                  40
Questions?

             41
THANK YOU FOR ATTENDING




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