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Finance and Procurement: Officer Accountability, Unrestricted Fund Expense Policy , Facilities and Administrative (F&A) Rates. Learning Objectives. Participants will be able to: Understand the new Officer Accountability Policy and apply it.
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Finance and Procurement: Officer Accountability, Unrestricted Fund Expense Policy, Facilities and Administrative (F&A) Rates
Learning Objectives Participants will be able to: • Understand the new Officer Accountability Policy and apply it. • Understand the new Unrestricted Fund Expense Policy and apply it. • Follow the Research Management and Support Accounts (formerly known as RF Funded) procedure • Explain how F&A rates are determined at the RF.
Officer Accountability Policy • Issued February 2012 as a result of some governance changes and audit findings • Policy updated as part of Operation Excelsior
Officer Accountability Policy Officers and Senior Executives are in positions of authority and are accountable for expenditure of certain RF funds and management of RF activities to accomplish their assigned responsibilities.
Officer Accountability Policy Operations Managers are now appointed officers of the RF
Officer Accountability Policy This policy establishes the requirements for independent review and approval of transactions that have a professional or personal impact on these Officers and Senior Executives
Officer Accountability Policy The purpose of the review is to assure compliance with established RF policies and procedures and appropriate management of actual or apparent or potential conflicts of interest or commitment that could arise from such transactions.
Officer Accountability Policy All transactions for operations managers must be approved by the campus president or delegate. • The delegate cannot be someone who reports to or is a subordinate of the OM.
What’s New? • Designate the Compliance Office at central office as the office of record for delegation forms • Expand the policy to include senior executives reporting to the RF President
What’s New? (con’t) 3. Require that campuses have a management plan to address the conflict when OMs are also a PI on sponsored projects or serve as officer or director of an affiliated organization.
Officer AccountabilityMultiple Choice Question: Operations Managers are now • Elected officers of the corporation • Appointed officers of the corporation • Board members • None of the above
Case Study 1 Scenario: OM submits a travel reimbursement request on a Research Management and Support (RF funded) account for travel to Tampa for a NACUBO conference.
Case Study 1 Action: Travel reimbursement must be approved by the campus president or campus president’s appropriate designee.
Case Study 2 Scenario: Your officereceives a travel voucher for the OM for hotel, mileage and meal charges for a trip to Albany for an OM related meeting. The travel request form is approved by the AP manager who is a report to the OM and the campus president has not designated an authorized signor.
Case Study 2 Action: Inform the OM thatthe travel must be approved by the campus president or that the campus president needs to designate an appropriate person on campus.
Case Study 3 Scenario: OM is also a PI on a sponsored project and travels to Chicago for a conference and charges the travel to his/her NIH grant. Should this be approved by the campus president or delegate?
Case Study 3 Action: Depends on campus conflicts management plan.
Unrestricted Fund Expense Policy • Addresses permissible and non-permissible expenditures of unrestricted funds • Ensures proper stewardship and appropriate use of funds
What is included in unrestricted funds? • Research Management and Support Allocations (RMS) (formerly RF Funded) • Cost recoveries for grants and contracts • Cost recoveries for shared services • Investment Income (when applicable) • Royalties • Other non-sponsored funding, including • Gifts • Fixed price balance accounts • Equity distribution from LLCs • Third party fees for use of service centers
Largest Impact? • Buying alcohol with unrestricted funds • Funds received from federal or state sponsors cannot be used to purchase alcohol • RMS allocations will identify sources of cost recoveries from federal and state sponsors • Separate RMS General accounts will be set up
Other Examples • Employee awards of nominal value is defined at $100 • Gifts to departing or retiring employees is defined up to $25 per year of service • Cash or cash equivalents must be treated as compensation and processed through payroll • Defines reasonable business meeting meals
Scenario 1 Answer: Yes or No Q: Are celebrations for completion of business projects and team successes a permitted expense? A: Yes
Scenario 2 Answer: Yes or No Q: While on a business trip, the department’s dean had dinner with several individuals from other institutions to discuss business. Should this dinner be included on his travel reimbursement? A: No
Scenario 3 Answer: Yes or No Q: A manager wants to give a cash award as an employee achievement, is this permitted? A: Yes
Scenario 4 Answer: Yes or No Q: A new recruit is in town for final interviews and a dinner with key personnel is held at a local restaurant. Is the total bill permissible no matter what the cost, including the alcohol? A: Yes
Research Management and Support (RMS) • Previously known as RF Funded • Gives better meaning to the use of these funds • Unrestricted funds allocated to campuses through the Operating Plan
Operating Plan • Displays how the RF earns and allocates unrestricted revenue during the fiscal year • Outlines the steps we will take to implement our Strategic Plan
Procedure • 80% of projected RMS allocations funded to a main account before start of fiscal year • Campus discretion to establish a RMS General account funded from ‘other’ recoveries
Facilities and Administrative (F&A) Rates at the RF • Campus F&A and fringe benefit rates are documented in a rate agreement with DHHS. • The agreements are all listed on the RF internal portal under “Rates”.
Long-form F&A Rates • Long form rates for schools over $10 million in direct costs covered by A-21 • Long form schools have several different rates • The base for the rates must be modified total direct cost (MTDC)
Simplified F&A Rates at the RF • Simplified (aka short form) rates for schools less than $10 million in direct costs covered by A-21. • Have two rates (on-campus and off-campus) for all activity • The base for the rates can be either: • salary and wage (S&W), or • modified total direct cost (MTDC)
F&A Rates Development • Generally every four years • Predetermined (rates are set and there is no adjustment or carry forward based over or under recovery) • Costs included are SUNY and RF costs at campus and central office and system admin as well as NYS and Construction Fund costs
F&A Rate Development Costs included in F&A rate Building Depreciation Equipment Depreciation Interest on Buildings Minor Rehab Costs Cost Campus Proposal CF Central Operating Costs NYS Campus Expend NYS Central Services RF Campus Expend RF Central Office Expend SUNY Central Expend
On-Campus and Off-Campus Rates “For all activities performed in facilities not owned or leased by the institution or to which rent is directly allocated to the project(s), the off-campus rate will apply.”
On-Campus and Off-Campus Rates Each campus chooses how the off-campus portion will be determined when a project is performed both on and off-campus. Generally outlined in special remark 2 or 3 in the negotiation agreement.
On-Campus and Off-Campus Rates Choice A50% rule: Grants or contracts are subject to only one F&A rate. “If more than 50% of a project is performed off-campus, the off-campus rate will apply.” Choice BCosts are apportioned: “Actual costs will be apportioned between on-campus and off-campus components. Each portion will bear the appropriate rate.”
Types of F&A Rates for Long- Form Schools • Research • Research DOD Contracts • Instruction • Other Sponsored Agreements (generally include public service and clinical trial awards) • Intergovernmental Personnel Act (IPA) • Nonfederal rates (at campus request)
F&A Question 1 Question: The type of F&A rates at the RF as defined by A-21 are? • Provisional • Predetermined • Fixed with carry forward • All of the above
F&A Question 2 Question: The A-21 dollar threshold for determining if a long form or short form (simplified method) F&A proposals is • $10 million in modified total direct costs • $ 5 million in total direct costs • $10 million in total direct costs • $ 5 million in modified total direct costs
F&A Question 3 Question: The off-campus option (50% rule or apportionment) selected by each campus is determined by total amount of direct costs. True or False. Answer: False.
Finance and Procurement: Officer Accountability, Unrestricted Fund Policy, Facilities and Administrative (F&A) Rates