WHO KNOWS WHAT LURKS IN THE PI MIND - WE DO

1. WHO KNOWS WHAT LURKS IN THE PI MIND - WE DO ONLY THE SHADOW (SYSTEM) KNOWS Randi Wasik, MBA, Director of Administration and Finance, University of Washington

2. THE AWARD LIFE CYCLE

3. AWARD ADMINISTRATION • Reasonable, Allowable, Allocable – the grant management holy grail • Put the correct charges on the correct fund right from the start. • Undue cost transfers are a compliance issue. • Reconcile fund activity monthly. • Process all corrections as quickly as possible. • Communicate with PI or designee monthly to review past expenditures and future projections. • Do projections / burn rate and include IDCs!

4. SHADOW SYSTEMS • Plan – they should serve both you and your faculty - transparency • Model so they can accomplish multiple goals • Be consistent • Do regularly • Get up and meet with your faculty to review and discuss • Have the faculty sign the reports • More than one set of eyes • Use electronic tools

5. COST TRANSFER DEFINITION • Transfer of cost from one institutional account to another • Cost transfers can occur between: • two sponsored accounts • from a non-sponsored account to a sponsored account, • from a sponsored account to a non-sponsored account, • between two non-sponsored accounts

6. EFFORT REPORTING • Federal regulations require that the effort of all individuals compensated or contributing effort to a federal project is verified. • Effort is percent of total time an individual spends on all work-related activities (research, teaching, patient care, administration, etc.) within their institution. • Cannot exceed 100%. • Not based on 40 hour work week. • Effort reporting certifies to the sponsors that effort committed to a project was completed.

7. SUB RECIPIENT MONITORING • Institutions are responsible for programmatic, administrative and financial monitoring of all awards made to sub-recipients under sponsored projects. • Institutions have an obligation to monitor the sub recipients activities throughout the life of the award. •  Responsibilities include - PI, Department and  Institution.

8. OTHER TRACKING NEEDS • Equipment • IRB • IACUC • Invoicing and Accounts Receivable • Scheduled Payments • Use for future budgeting and forecasting • Plan, forecast and account

9. REPORTING • Financial Reports: • All expenditures posted? • All expenditures appropriate? • Equipment reports • Who owns the property now: Institution or Sponsor? • What is its distribution? • Is it still being used?

10. REPORTING, CONTINUED • Releases (Normally for Contracts)Payment linked to timing or milestones/deliverables • Deficit Balances (Overruns) • Cannot be shifted to other awards • Cannot be included in F&A cost pools • Surpluses • Cost Reimbursement Agreements – Returned to Sponsor • Fixed Price Agreements (including Clinical Trials) – Retained by Institution

11. AUDITS • Anticipate the project will be audited. • Manage the award correctly from the beginning. • Audits often take place several years after the project is completed. • Organized Files • Documentation for expenses including explanations of why items were charged • Appropriate Approvals • Audit Trails

12. Research Stewardship and Compliance: Principles and Responsibilities Cost Policy and Financial Management Principle: Ensures fair and reasonable costs to the Government. Reasonable Allocation of Costs, Effort Reporting, Sub-recipient Monitoring, Cost Transfers, Indirect Costs, Cost Sharing Conduct of Research Principle: Ensures validity of results & maximizes return on public investment. Conflict of Interest, Research Integrity, Data, Resource Sharing, Cyber Security, Public access to Publications, Conflict of Commitment Protections/Safeguards Principle: Provides for welfare of researchers, subjects, & environment. Human Subjects, Animal Welfare,HIPAA, Select Agents, Radiation, Environmental Health & Safety, Hazardous Materials, Radiation, Recombinant DNA, Lab safety Public Policy Principle: Meets national social, economic, & security interests. SEVIS/Visas, Export controls Race, Gender, & Handicap Equality & Education, Lobbying, Debarment, Drug Use, USA Patriot Act Originally Created by Geoff Grant, Partners Health Care

13. Florida International Univ.Effort Certification & Direct Costs $11.5 million Impact of Non-Compliance Johns Hopkins Univ. Effort Certification $2.7 million University of MinnesotaMisuse of federal funds $32 million New York University Medical CenterInflated Research Grant Costs$15.5 million Univ. California, San Francisco Animal Care Allegations $92,500 fine Univ. of Southern CaliforniaQuestioned Costs HHS/OIG Audit $400,000 Significant Audits & Settlements Mayo FoundationMischarging Federal Grants $6.5 million East Carolina UnivQuestioned Costs HHS/OIG Audit $2.4 million Univ Alabama, BirminghamEffort Certification & Clinical Research Billing $3.4 million Cornell MedicalClinical Research Issues $4.4 million Harvard/BIDMC Costing Issues (Self-Reported) $3.25 million Northwestern University Committed Time/Effort $5 million

14. DISCUSSION and QUESTIONS