Roles and Responsibilities Principal Investigators University of Missouri – St. Louis

1. Roles and Responsibilities Principal Investigators University of Missouri – St. Louis College of Education February 11, 2009

2. Learning Objectives • To understand: • Principal Investigator (PI) responsibility for sponsored programs • Key fiscal compliance requirements • Common issues and impact of non-compliance

3. Overview • Definitions • Compliance Requirements • Responsibility • Common Issues • Concluding Points

4. Definitions • Sponsored Award – Activities related to a proposal funded by an external entity for a specific purpose. • PI/Co-PI – Principal Investigator. Named by sponsor on award document with ultimate responsibility for ensuring compliance. • Fiscal Officers – the individual assisting the PI with the administrative management of an award.

5. Definitions • Unallowable costs – Costs charged to an award not meeting the requirements. • APM – Accounting Policy and Procedures Manual. Codification of accounting policies. • BPM – Business Policy Manual. Codification of business and administrative policies.

6. Compliance Requirements Who sets the requirements? • Office of Management and Budget (OMB) – Oversight agency for the federal government • OMB Circulars – The federal rules for how awards are to be administered. • Sponsors – Individual sponsors may have additional requirements • APM and BPM – policies established jointly by Campuses and UM System

7. Compliance Requirements Who enforces the requirements? • External Auditors – Identify questionable costs and internal control issues. • Office of Inspector General (OIG) – Final enforcer of requirements. May require funds be returned to sponsor, impose fines, and/or sanctions.

8. Compliance Requirements Whatcompliance requirements apply to sponsored programs? • OMB Circular A-21- Cost Principles for Educational Institutions • OMB Circular A-110 - Administrative Requirements for Grants and Agreements • OMB Circular A-133- Single Audit Requirements • Specific Sponsor Administrative Guides

9. Compliance Requirements When do these requirements apply? • Receipt of direct federal awards • Awards containing federal flow-through dollars • Awards where terms and conditions reference OMB Circulars However, the University requires all awards to follow the requirements for federal awards.

10. PI Responsibility • General Compliance and Oversight • Project Planning and Proposal Submission • Award Set-up • Management During the Award • Award Closeout and Reporting • Effort Verification Reports • Cost Transfers • Cost Sharing • Subawards

11. 1. General Compliance, Oversight • Aware of applicable requirements • OMB Circulars, University policies • Sponsor restrictions • Ensure compliance • Attend training • Work with Fiscal Officer • The PI has the ultimate responsibility

12. 2. Planning/Proposal Submission • Complete proposal timely • Obtain all approvals (PSRS) • Manage technical/programmatic negotiations with sponsor • Establish pre-award accounts • Ensure all costs are allowable and unlike circumstances are justified

13. 3. Award Set-up • Notify ORA upon receipt • Delegate authorization • Ensure accuracy of budget in PeopleSoft • Identify federally funded equipment • Establish payroll distribution of effort - PAF See APM 60.35 – Establishing an Award

14. 4. Management of Award • Monitor project timely • Ensure all expenses are authorized • All charges are allowable • Notify sponsor for significant changes • Supporting documentation exists

15. 4A. Monitor Project Timely • Managerial review monthly: • All costs are posted and allowable • Within the period of availability • Unreasonable or unusual activity • Address budget deficits or excess costs • Notify sponsor if significant changes • Sign/date documentation evidencing review See Segregation of Duties – APM’s 2.25.55 and 2.25.55.01

16. 4B. Proper Authorization • Ensure all expenses are authorized • PI may delegate authorization: • Direct knowledge of the sponsored award • Aware of terms and conditions • Aware of compliance requirements • University employee See APM 2.25.55.01 – Segregation of Duties – Sponsored Programs and 2.25.55.02 – Delegation Form

17. 4C. Allowable Charges • Ensure all costs are allowable • Per OMB (A-21) and sponsor requirements • Allowability requirements: • Reasonable • Allocable • Consistent Treatment • Conform to limitations or exclusions

18. 4C. Allowable Costs • Direct costs must be: • Identified specifically for a particular sponsored award • Directly assigned with relative ease and a high degree of accuracy • Consistently treated in like circumstances • Supported by documentation

19. 4C. Allowable Costs • F&A is: • Incurred for a common or joint objective (e.g. utilities) • Cannot be easily identified with a particular award • Facilities: depreciation, interest on related debt, operational, maintenance, and library costs. • Administration: departmental, sponsored projects, student services, and other general administrative costs.

20. 4C. Allowable Costs • Certain costs are expressly unallowable: • Alcoholic beverages • Alumni activities • Bad debts • Donations and Contributions rendered • Entertainment • Furnished automobile – personal use • Goods or services for personal use • Housing and personal living • Losses on other sponsored agreements

21. 4C. Allowable Costs • Certain costs are unallowable with exceptions: • Contingency provisions • Fines and penalties • Fundraising and investment costs • Lobbying • Pre-agreement costs • Selling and marketing costs • Student activity costs • Must be specified in the agreement to be allowable!

22. 4D. Notify Sponsor • Notify sponsor when there is a: • Change in scope or objective • Significant change in budget • Change in key person specified in award • Absence of the PI for more than 3 months, or a 25% reduction in time devoted • No-cost time extension • Work with ORA to notify sponsor

23. 4E. Supporting Documentation • What is considered adequate documentation? • Sufficient Documentation should state: • the charge is allowable, and • the charge directly benefits the related award. • Substantial Documentation (for cost transfers > 60 days old) should address: • Who, What, When, Where, and Why? • How will error be prevented in future?

24. 5. Award Closeout & Reporting • Ensure awards are closed timely • Review notice of award closings • Closeout deficits • Provide final technical reports • Certify allowability of costs • Documentation exists for all costs See APM 60.20 – Closing Sponsored Awards and APM 60.07.01 - Certification

25. 6. Effort Verification Reports • Ensure all payroll costs directly charged reflect actual efforts • All EVRs are reviewed, signed, and completed by due date • Signed by person with suitable means • Update payroll records for differences > 5%. • Note: 100% funding of PI is red flag See APM 60.32 – Effort Verification Reports

26. 7. Cost Transfers • A reallocation of costs to an award after the transaction has occurred • To correct an error • All cost transfers should be: • an allowable and allocable charge, • properly documented, and • made in a timely manner. See BPM 213 – Adjustment of Income and Expense Items

27. 7. Cost Transfers • Cost transfers should not be done to: • Meet budget deficits • Avoid restrictions • Shift unrestricted budget • Spend out unused award budget • For other conveniences • Red flag if excessive transfers at end

28. 8. Cost Sharing • At proposal: • Identify funding source • Obtain appropriate approvals • Document exceptions in agreement • During the award: • Ensure cost sharing requirements are met • All cost sharing is allowable • Documentation exists to support

29. 9. Subawards • Determine the need, scope, and budget for subaward • Ensure proper classification • Monitor progress and deliverables • Review and approve payments • Subject to same compliance requirements See APM 60.85 – Subrecipient Monitoring Procedures

30. Common Issues • Unallowable costs on projects • Lack of documentation: • Cost Transfers • Cost Sharing – supporting requirements • Incomplete and/or late EVRs • Late cost transfers • Purchases in last 3 months of award • Delay in filing final reports

31. Impact of Non-Compliance • Questioned or unallowable costs • Repayments to the sponsor • Fines and/or sanctions • Subject to additional external audits • Jeopardize future funding opportunities • Damage to reputation

32. Checklist for Success • Ensure costs are: • Authorized in the budget & agreement • Charged timely to the project • Meet the requirements of allowability • Timely review budget and costs • Make timely and allowable cost transfers • Appropriately document all costs

33. References Where can I get more information? • OMB Circular A-21 • University Controller’s Office Policies – APM – Section 60 • Reference Guide for Sponsored Programs • PI Roles and Responsibilities • Facilities & Administration Fiscal Misconduct Hotline

34. Contact Information • Tina Hyken • Business and Fiscal Operations Specialist • 314.516.5127 • Hykent@umsl.edu • Karen Boyd • Manager, Business/Fiscal Operations • 314.516.5923 • boyd@umsl.edu