Effective Project Administration Guidelines | Effort Reporting, Cost Transfers, Subawards

1. Highlights of Post Award Sponsored Project AdministrationJuly 11, 2007Office of Research Training & Compliance

2. Topics Covered • Effort Reporting • Cost Transfers • Subawards • Independent Contractors • Subrecipient Monitoring

3. What is Effort? • Total professional effort is the amount of time spent on ALL activities including both University (instruction, departmentally-funded tasks, funded research) and non-University (i.e., clinical services). • Effort is not based on a 40 hour work week but rather a percentage of effort and must equal 100%. • Effort distributions should be reasonable estimates of activities. Effort includes both direct charged and cost shared effort.

4. Effort Reporting(A-21 requirement) • GW policy requires that the Effort Certification Report be signed by the employee, PI or responsible official using suitable means of verification that the work was performed. Complete semi-annually: Jan-June and July-December. • Effort Certification is not how payroll expense is distributed. • Change in Status (CIS) forms are required to be processed when there is a substantial change in the employee’s effort. • Review monthly labor distribution reports to ensure compliance.

5. What are Cost Transfers? Cost transfers are after-the-fact re-allocations of costs, either labor or non-labor to a sponsored project. Personnel Costs/Non-personnel - CIS/DCF forms that correct a variety of data entry, admin and acct coding errors - CIS/DCF forms that transfer costs between continuations of projects or related project/awards - CIS/DCF forms that transfer pre-award costs

6. Exclusions • Initial allocations of costs from interfaces, service centers and clearing accts, including suspense and failed funds (N.B., these are not cost transfers b/c they do not involve reallocations) • CIS forms that re-distribute salary for a prior period to an award prior to effort cert. (N.B., these are not cost transfers b/c the original allocation is an estimate, so the redistribution of charges is a revision of an estimate) • Credits to awards (N.B….b/c they do not involve allocations of costs to a sponsored project)

7. Why Document? • Reguations specifiy. Every cost transfer must be documented. • Must include info on how the error occurred and approval/certification of the correctness of the transfer by the organizational official. • For standard cost transfers, initiators should use the remarks box on the relevant CIS/DCF forms.

8. Cost Transfers that require a memo to the Comptroller • The correction is initiated 90 days after the error and/or 30 days after the award has been closed; • The cost is being transferred for the second time; • The costs is being transferred to a sponsored project or task to correct a cost overrun on a related sponsored project or task; • Salary costs are being transferred after the certification of effort associated with the costs; • Any other circumstance in which the certifying official needs additional documentation to verify the cost is allowable.

9. Sub-awards • Sub-awards are a formal legal agreement between GW and another legal entity where: - a defined portion of our sponsored project’s scope of work (intellectual activity) is assigned to another entity (“the sub-recipient”) to fulfill; - Work is performed by the sub-recipients personnel, using their resources, usually at their site; - Terms and Conditions from GW’s prime award are flowed down to the third party sub-recipient. - Pass through entity’s F&A rate is only charged to the first $25,000 of each subaward. - Sub-awards can sometimes be referred to as sub-grants, sub-agreements or subcontracts. If the prime award is a contract, then the sub-award is subject to procurement regulations.

10. Independent Contractors • Provide goods/services within normal business operations • Sell to the general public • Operate in a competitive environment • Provide goods and services that are ancillary to GW’s sponsored project. • IP is generally owned by the Company • Non-University Labor or Services (Twenty Factors Test)

11. Subawards Documentation required at proposal submission from PI: OCRO Checklist Fair & Reasonable Cost Analysis Independent Contractors At proposal submission: Budget and Statement of Services from Contractor - Resume (if individual) Postaward: - Selection of Source form Supplier registration if new supplier Twenty Factors Documentation Requirements

12. Sub-recipient MonitoringA-133 Requirement • Ensure that monies funded to us from a federal awards are used for authorized purposes and are in compliance with laws and regulations of the prime award • Ensure that goals and objectives of the work proposed by the sub-recipient are achieved • Monitor invoices of sub-recipient closely to ensure funds are spent appropriately and work is satisfactory and within time constraints. Communicate deficiencies to sub-recipient in a timely manner! Did the sub-recipient commit to cost-sharing? If so, this must be monitored!

13. Sub-recipient Monitoring (cont.) • GW sub-recipient agreements require the sub-recipient to submit a final report or reports that the PI instructs. These reports will be incorporated into GW’s final report to the sponsoring agency. • Ensure timely closeout! 90 days before end of subaward, confer with sub-recipient. If more time is required, GW may need to request a no-cost extension from our prime sponsor.

14. Policy Sites • http://my.gwu.edu/files/policies/CostTransfersSponsoredAgreementsFINAL.pdf • http://my.gwu.edu/files/policies/EffortCertificationFINAL.pdf • http://my.gwu.edu/files/policies/Bids,Quotes,SoleSourceFINAL.pdf • http://my.gwu.edu/files/policies/SubrecipientPolicyFINAL.pdf