Post Award Administration of Sponsored Projects

1. Post Award Administration of Sponsored Projects

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3. 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

4. 4 Grants Accounting Office

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6. 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 P-Card charges made after the 26th of the month post on the following cycle 6

7. 7 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)

8. 8 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

9. 9 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

10. 10 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

11. 11 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 P-Card charges made after the 26th 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

12. 12 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

13. 13 Expenditures What does Grants Accounting look for when monitoring expenditures? Would you like to know how your expenditures can FLY through the review process?

14. 14 Expenditures Prepare expenditures to FLY on the: Timing Allowability Reasonableness Money Allocable Consistent

15. 15 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.

16. 16 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? Money Available funds in budget category Re-budgeting may require sponsor�s prior approval Grant Budget Reallocation Form

17. 17 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

18. 18 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

19. 19 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

20. 20 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

21. 21 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

22. 22 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

23. 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

24. 24 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

25. 25 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

26. 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

27. 27 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

28. 28 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

29. 29 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

30. 30 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

31. 31 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

32. 32 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

33. 33 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

34. 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)

35. 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

36. 36 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

37. 37 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

38. 38 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

39. 39 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!

40. 40 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

41. 41 Questions?

42. 42 THANK YOU FOR ATTENDING