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Coffee With OSP

Coffee With OSP. Compliance requirements related to: Effort Verification Reporting (EVRs) Cost Transfers Payroll Correcting Entries (PCEs) Journal Entries Summary of Internal Audit of PCEs. Follow Up of Compliance Training Conducted on 04/16/08.

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Coffee With OSP

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  1. Coffee With OSP Compliance requirements related to: Effort Verification Reporting (EVRs) Cost Transfers Payroll Correcting Entries (PCEs) Journal Entries Summary of Internal Audit of PCEs Follow Up of Compliance Training Conducted on 04/16/08 Slide excerpts from Ericka’s Kranitz

  2. EVR Compliance Requirements To ensure payroll costs directly charged to an award reflect actual efforts Reflects 100% of all activities (research, teaching, administrative) Plan Confirmation Method –initially based on budget – updated to reflect actual efforts Significant changes updated timely Signed by person with “suitable means of verification that work was performed.” Refer to APM 60.32 – EVR policy

  3. Cost Transfers – Compliance Requirements What Is It? Cost Transfer—A reallocation of costs to an award after the transaction has occurred To correct an error Costs should not be accumulated elsewhere and later transferred to award Supported by DOCUMENTATION as to “why” making transfer Made timely and have proper approvals if over 60 days

  4. Cost Transfers – Compliance Requirements Transfer should directly benefit the project and be: Allowable Reasonable Consistently treated Within Period of Availability Reasonable allocation methods for multiple awards

  5. Cost Transfers – Compliance Requirements Cost transfers may not be done: - To meet deficiencies caused by overruns or other fund considerations; - To avoid restrictions imposed by law or by terms of the agreement; - To shift unrestricted budget or - To “spend out” unused award budget

  6. Cost Transfers - PCEs To redistribute payroll charges when actual efforts differ > 5% Make corrections within 60 days of transaction* If over 60 days, approval by individual, PI, Department Chair, and Dean Must be an allowable cost and directly benefit the project. DOCUMENTATION to justify *Refer to BPM 213 – “Adjustment of Income and Expense Items

  7. Potential Red Flags Late cost transfers (including PCEs): Evidence untimely monitoring Difficult to document justification Transfers in last 3 months of grant Trying to spend out the award PCEs over 90 days after original transaction Federal Sponsors are disallowing corrections of more than 90 days Incomplete EVRs and PCEs Unsigned EVRs lead to disallowed cost PCE not signed by PIs lead to disallowed cost Insufficient DOCUMENTATION

  8. Risks of Noncompliance Result in questioned or unallowable costs Repayment of monies on current award Jeopardize future funding opportunities Department is responsible for unallowed costs Fines and sanctions

  9. Summary of Internal AuditAging of PCEs

  10. Summary of Internal Audit--PCEs Main issues: Unreasonable time between original payroll transaction and PCEs processed Insufficient justification/documentation Improper or incomplete approvals

  11. Questions ? ? ? ? ? ? ? ? ? ? ? ? ? ? ?

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