WSU Research Administration Series: Research Administration Update

1. WSU Research Administration Series: Research Administration Update Nancy Shrope, OGRD Kim Small, Sponsored Programs Heather Lopez, Internal Audit September 20, 2013

2. Recording date of this workshop is September 20, 2013 Some of the rules and procedures discussed in this workshop are subject to change. Please check university resources before relying exclusively on this recorded presentation.

3. Why are we here today? This 13 part series is designed for those employees that have sponsored management responsibilities to gain a better understanding of what research administration is made up of - the pre-award and post-award processes, requirements and compliance from A to Z.

4. Office of Grant & Research Development • Research Development Resources • Proposal and Award Processing Services • Training and Outreach Sponsored Programs Services (SPS) • SPS Role and Responsibilities • Updates Audits • Purpose • Internal and External Auditor Roles • Types • Negative Effects • Common Findings • Issues and Reminders

5. OGRDOffice of Grant and Research DevelopmentPre-Award

6. Training and Outreach OGRD Assist Faculty and Graduate Students to Obtain Extra Mural Funding Our Mission

7. OGRD Identify & Disseminate Funding Opportunities • COS Pivot funding database & training • Informer • Limited submission • WSU Scholars Expertise Profile Proposal Management Unit (PMU) • Support for large interdisciplinary proposals • RFP review, timeline assistance, meeting coordination • Provide templates/models, editing, budget support • Help with special needs and proposal submission

8. OGRD Graduate Student Support • Provide assistance and resources for extramural funding • Graduate student funding announcements • Graduate proposal writing workshops • Training at graduate student orientations

9. OGRD Grantsmanship Training • Writing Winning Grants Seminar • Mentored Proposal Writing Program • Productive Proposal Writing Class Proposal Development Resource e-LibraryOutreach & Collaboration Building Activities • Coordinate meetings, workshops, seminars and state-wide outreach activities • Coordinate WSU internal grant competitions • Promote prestigious faculty awards & provide applicant support

10. OGRD Review and Authorize Proposals and Awards • Provide guidance on RFPs and/or help with forms • Review of final proposal • Submission of proposal to sponsor • Tracking and monitoring of proposal • Budget preparation and certification • F&A issues • Accept awards (grants, contracts, purchase orders) Prepare, Negotiate & Execute Agreements & Contracts • Draft various subawards and contracts • Review contractual language • Material transfer, non-disclosure, no-money, data set and equipment loan agreements

11. OGRD Certify and assure university adherence to governmental policies • U.S. Code of Federal Regulations and other federal regulations • OMB Circulars • Revised Code of Washington (Title 28B) • WSU Business Policies & Procedures Manual • WSU’s Faculty Manual Monitor and report sponsored project activity • Work with SPS and sponsor on award changes • Help with additional materials Advise faculty, staff & graduate students on these functions & activities

12. OGRD Cool Stuff • Received funding for the Health Sciences building in Spokane • Largest USDA award ever made for biofuels research-$40 million • $900 million in 2370 proposals submittedwithFY13 1850 awards received for $237 million Reporting is HUGE • Work with Institutional Research to give them all our numbers to determine WSU's national ranking • Data shack or canned reports are now available through MyResearch (Training provided: contact Derek Brown for dates)

13. OGRD Hot Issues - • Financial Conflict Of Interest (medium hot!) • Soft Funding Reminder - Sign up for the WSU Research Admin list serve. Contact Derek Brown to signed up.

14. OGRD www.ogrd.wsu.edu • RAC list, quick guide, policies, guidelines, templates, etc. https://myresearch.wsu.edu • OGRD Database www.grants.gov; https://www.fastlane.nsf.gov/fastlane.jsp • Federal generic proposal submission sites informer.ogrd.wsu.edu • funding opportunities www.youtube.com/user/WSUOGRD • Grant & funding tips for the greater WSU community http://www.facebook.com/pages/Office-Grant-Research-Development-OGRD-WSU/185924391445269?ref=hl • Find us on Facebook

15. Sponsored Programs Services (SPS) Post-Award

16. SPS’s Role As WSU Post Award Office • Provide fiscal administration. • Educate and train. • Establish accounts and input budget allocations. • Maintain data systems and project files. • Prepare, submit & record financial reports & associated payments. • Subcontract payments. • Periodically notifying departments of overdrafts. • Draw funds from federal government, prepare receipts for checks and electronic funds transfers.

17. SPS Updates • F&A Rates • E-Verify (FAR clause 48 CFR 22, Subpart 22.18) • Excess Compensation • Stipends / Fellowship Payments • Subrecipient Monitoring • Cost Transfers • Effort Reporting / Cost Share

18. F&A Rates (On-Campus) • 51% rate is the current rate for on-campus awards • 50% rate is applicable only after 7/1/11 • 51% rate is applicable only after 7/1/12 • The rate changes are based upon the state fiscal year.

19. E-VERIFY • E-Verify is an internet-based system, operated by the US Department of Homeland Security in partnership with Social Security Administration. The program compares the I-9 information reported to US government records to determine employment eligibility. • We have 3 business days to enter the names of the employee(s) into the online E-Verify system. • It is the department’s responsibility to give HRS the namesof the employees once they know they are going to receive the award.

20. Excess Compensation/Faculty Timecards • SPS approval is required for faculty time cards that are charged against a sponsored project. • Since this is the mechanism for paying faculty for duties above and beyond or outside their normal duties, this is usually an unallowable expense on a grant. • Excess compensation for the PI is obvious. • Not so obvious is paying other, non-grant faculty for their time and assistance.

21. Excess Compensation/Faculty Timecards… • Say you want to pay a WSU faculty member a travel allowance for attending your conference, or an honoraria for participation, or even payroll for guiding/mentoring a summer project • If that faculty member is already at 1.0 FTE for that time period – this translates to Excess Compensation. • Excess Comp has the same regulations and requirements at this point in the project as at initiation. • See OGRD guideline #21 • See A-21 section J(8)(d)(1) • To approve this request SPS will require: • Agency approval & Provost office approval – specifically stating it is allowable to pay excess compensation for this person.

22. Stipends • Stipends and Fellowships should be paid as object 08 rather than as wages and benefits. • When we pay the student as wages we are shorting the students the amount of money they were awarded. • It is the student's responsibility to report the income and pay the taxes on it if owed. • The idea of paying wages and benefits suggests that the student is required to do something in order to receive the funds.

23. Subrecipient Monitoring • This is an ongoing requirement that bridges from subcontract initiation to closeout. • It is shared and documented in the department, in OGRD and in SPS. • There is a class in this series that will go through WSU’s subcontracting process and help you define who is responsible for doing which parts and how it all ties together.

24. Cost Transfers • It is the expectation / understanding that the expense was initially applied correctly. • Now the story is “we have changed our mind”. • Be sure your transfers are timely with complete information. • 90 day justification

25. Effort Reporting • The proportion of time spent on any activity; expressed as a percentage of WSU compensated time. • Salaries/Wages must reflect actual effort expended and not the proposed/budgeted effort. • Effort Reports account for the total activity an employee is compensated for and required to fulfill their obligations to WSU.

26. Effort Reporting • WSU's Effort Certifications use an after the fact determination so that the cost distributions represent actual costs based upon actual effort. • Effort Certifications are distributed 4 times a year. Based upon semester (2 summer) They are run the month following the end of the semester so they include all the information for that semester. • It is the expectation that all Effort Certs will be returned within 90 days.

27. SPS Website • http://sps.wsu.edu/ • Contact information • Who does what • Expenditure Information in various formats

28. Audits

29. Purpose of Audits • Required • By accepting federal money, grantee agrees to comply with rules • Grantor has an expectation for • Accountability • Proper stewardship • Terms carried out – results, product, service, etc

30. Role of Auditors – Internal or External • Auditors test to ensure, and, opine on whether management has adequate controls and processes in place to: • Comply with applicable rules • Adequately safeguard resources • Properly present and report activity

31. Role of WSU Internal Audit • Act as liaison between WSU and external auditor • With SPS and unit, ensure information requested is provided complete and accurate to support conclusions • Work with auditor on reporting • Internal advisory for management on controls, policy, training • Audits and investigations

32. Types of Audits • Compliance • Circular A-133, ‘Single Audit’ • Program reviews • Financial Statement • Operational • reviews • Investigations

33. Effects of a Negative Audit Report • Loss of future awards • Bad publicity • Potential undermining of public trust and confidence in agency and government • Personal losses

34. Common Issues • The following are some examples of common issues that may result in questioned costs and subsequent cost disallowances: • Lack of time records to support labor costs charged to awards. • Lack of consulting agreements and invoices to demonstrate allocability to the award and that the charges are reasonable. • Indirect cost recovery charges in excess of the amount allowed by the type of indirect cost.

35. More Common Issues • Costs that are unallowable in accordance with applicable cost principles and, therefore, cannot be charged to Federal awards. • Proposed participant support costs that were re-budgeted to other cost categories without the required written approval of granting agency. • Inadequate supporting documentation for expenditures claimed as cost sharing.

36. Changes Pending: Circulars On February 1, 2013, the Office of Management and Budget released a notice of proposed guidelines entitled: Proposed Uniform Guidance: Cost Principles, Audit, and Administrative Requirements for Federal Awards The proposal, also being referred to as “The Super Circular”, combines the multiple Federal regulations that currently govern the way we administer grants into a single, comprehensive and streamlined uniform policy guide.

37. 8 Circulars to 1

38. Stay Tuned…. • As changes to the Circulars become final, communications and training will be provided to the research community. • Potential impacts: • Audit (audit process and program determination, thresholds changing, responsibilities → greater sub-recipient monitoring requirements) • Cost principles (changes to allowed cost, admin costs, time and effort, procurement) • Administration (organization, reporting linked to performance)

39. Audit reminders • When approached by external auditor: • Always verify auditor’s credentials before giving information • Notify supervisor and SPS • Notify Internal Audit • Be prepared • Be organized • Do it right the first time

40. Resources • WSU Sponsored Programs Service • WSU Office of Grant & Research Development • Internal Audit – 5-2001, hlopez@wsu.edu • OMB Circulars - http://www.whitehouse.gov/omb/circulars/ • SAO – http://www.sao.wa.gov

41. This has been a WSU Training Videoconference If you wish to have your attendance documented in your training history, please notify Human Resource Services within three days of today's date: hrstraining@wsu.edu