Grants Management

Grants Management Dr. Monica Swahn Associate Vice President for Research mswahn@gsu.edu / 404-413-1148 April 19, 2012

Overview of rules, regulations, and procedures necessary to manage an externally funded project Review Principle Investigator’s (PI) responsibilities Summary of information of PIs necessary responsibilities Understanding “why” this is important Objectives

University Research Services & Administration (URSA) • URSA provides faculty support for proposal preparation, awards management, research compliance and safety, and other aspects of research • Awards management • Who we are (org chart; department assignments) • Manuals, policies, forms • Website at: www.gsu.edu/research/index.html

Office of Sponsored Programs (OSP) Marca Gurule, Associate Director Handles non-financial aspects of grants management Any official contact with agency officials Research Financial Services (RFS) Michael Mathisen, Associate Director Accounting of expenditures Generating financial reports Continue – University Research Services & Administration (URSA)

A sponsor awards Georgia State University Research Foundation (GSURF) that subcontracts out to Georgia State University’s (GSU) funds Expectation is that GSU has policies and procedures in place to make sure funds are spent according to Federal guidelines and are not misused Auditors come on campus to check Roles and Responsibilities of Georgia State University Employees Engaged in Sponsored Project Management and Oversight are on URSA’s website Roles & Responsibilities

The Beginning Getting an Account Number Terms & Conditions of Award Notice of Award

Both PIs and OSP may receive notifications If PI only receives, then must send to OSP within 7 days OSP will likewise send to PI Negotiations: Changes in budget by sponsor may mean PI wants to make changes in goals/scope of work Done by PI, in consultation with OSP and Legal Affairs (if contract) All major changes to budget should be “re-routed” using Proposal Approval Form Don’t announce to public until get “official notification” (and agency allows you) Notice of Award (NOA) (NGA)

Notice of Grant Award (NGA) Letter Check Contract PIs are not the “authorizing official” of GSU OR GSURF Can’t sign anything for University Notice of Award

Must get IRB/IACUC approval prior to establishment of project number Can get approval for general methods and make amendments later Letters of cooperation from sites Obligated to comply with all regulations involving human subjects, animals, health and safety. Get copies of compliance letters from subcontractors, other sites Compliance

Proposal Approval Form PI certified to adherence of GSU’s: Conflict of Interest Policy Intellectual Property Policy Terms and Conditions of Award Follow all relevant GSU, State of Georgia, Federal laws, and regulations Certifications

Regulatory Hierarchy How is the Regulatory Hierarchy Determined? OMB Circulars A-21 or A-122, A-110, & A-133 Agency Policy Manual (i.e. NIH GPS, NSF GPM, DHHS, & Selected FAR Clauses Terms and Conditions of Award Notice University’s Policies and Procedures You 11

“Green Sheet” issued by OSP Done after official NOA & Compliance requirements Based on information from Proposal Approval Form & NOA Speedtype or Project ID SP000 plus 5 numbers (e.g., SP00010111) OSP & RFS Officers Project Number

Account numbers – code source of funding Federal, state, nonprofit, and for-profit Types of projects Research, basic, and applied Instruction Other Project Number

Budget categories set up based on awarded budget “Funded” based on annual budget, even if awarded 5 years Budget

Cost Share • Cost sharing is when PIs commit “other” resources to pay for some of the costs associated with a sponsored project • Noted on Proposal Approval Form and submitted budget or just in the narrative • Should only do it when is required • But, if in proposal, must document • Can cost share anything that can be a direct cost on a project

Companion accounts for cost share Must have funds transferred using a budget amendment Cost Share

Project reports (both technical and financial) Close out Cost accounting principles Requirements regarding making changes to original proposal (Prior Approval) Some changes PI can make without any approval Some changes require approval from sponsor Expanded authorities (Federal Awards) authorizes institution (via OSP) to approve some changes Terms & Conditions (T&C)

Need agency approval for: Change in scope or specific aims Change in methodology (may not need approval) Change in Key Personnel. PI always needs OSP and agency approval. Other personnel depends on T&C T&C: FederalTechnical (Non-Financial) Issues

Expanded authority allows expenditures 90 days before start date for Federal grants Need to set up account through Institutional Prior Approval System (IPAS) Pre-Award (defined as period before official start date) Advance Account (prior to receiving official notification) Requires chair and dean authorization T&C: Preaward Costs

IPAS Form • Available under Awards Management: • www.gsu.edu/research/awards_management.html • Select IPAS - Institutional Prior Approval Form

Depends on T&C: Make sure you know! Ask OSP!!! GSU requires an IPAS completed if change is more than 25% of a budget category Expanded authorities allow change in expenditures of a single cost category in original budget up to 25% of the total costs. More need agency approval Purchase of equipment may need agency approval (NIH > $25,000) Travel may need approval (especially foreign) Can’t transfer between indirect and direct costs Can’t transfer from participant support costs T&C: Rebudgeting

Carryover of unobligated balances from one budget period to another may be automatic (IPAS Form not necessary) NIH requires indication in progress report if estimated unobligated balance (including prior-year carryover) is expected to be greater than 25 percent of the current year’s total approved budget T&C: Carry-Over Funds

Expanded authorities allow request for one-year no-cost extension past the project end date (IPAS Form) Must be “prior approval” request to OSP before end date of the grant and best if submitted one (1) month before Any further requests for no-cost extensions must be done to the sponsor. Make request through OSP T&C: No Cost Extension

Fiscal Management Expenditures

Direct Cost Policy • Federal Cost Accounting Principles • Costs charged to a sponsored project must be directly beneficial to project: • Personnel (salaries and fringe benefits) • Subcontracts • Consultants • Supplies for research • Equipment (more than $5,000) • Travel

Charge Costs that are allowable Direct Costs are: Reasonable:Would a reasonable person think this was a cost for this sponsored project? Allocable: Be attributable to project. But can be distributed proportionally between projects if use some reasonable basis for the distribution Allowable: Must be a cost that is permitted to be charged as a Direct Cost Direct Cost Policy

F&A also known as Indirect Costs Costs to support research such as building depreciation, libraries, operation and maintenance, general departmental administration, and support for conducting research Percentage of the Direct Costs Split between University and College/Dept Should be used (to the extent necessary) to support project Facilities and Administrative Costs (F&A)

Examples of costs typically not charged as Direct Costs because considered Indirect Costs: Administrative and Clerical Costs Printer Toner, Copy Paper, Copying Costs Cell Phones/Telephone service Routine Postage General Office Supplies and Equipment Computers (unless scientifically justified) PDAs/Blackberries Indirect Costs

If above “routine” use of these items (e.g., distributing classroom material, surveys) Or project is considered a major project (definitions in policy) Or need a computer for an exclusively scientific use Exceptions to the Rule

Justification establishes reason for exception Putting item in approved budget not sufficient Have to include it in budget justification with a reason that indicates why it is an exception at the time of application (so approved by agency) If not in approved proposal has to be reviewed on a case by case basis by OSP Officer Exceptions require Justification

Costs that are typically not allowed: Food Allowed when traveling away from ATL Food for participants, typically an exception, but need to get sponsor approval Alcohol Never allowed except for scientific purposes Follow GSU’s standard rules Unallowable Direct Costs

Expenses are audited for presence of unallowable costs Charges at Staples, Office Depot, etc. are always suspect Need good documentation If no Indirect Costs charged to the project, then okay Audit: Direct Cost Policy

Personnel • Defined as Georgia State University’s Employees and must comply with GSU’s Human Resource Policies: • Faculty • Graduate Students • Staff

Commitment = payroll (salary) = effort T&C will tell you who they consider “committed” PI and other faculty Commitment is what you specified in your grant application or approved budget (commitment is for the budget year) Not specific to the academic year or summer So “fulfill” your commitment anytime during the budget year Personnel: Faculty

Effort Commitment • Academic year, typically, corresponds to a course buyout but doesn’t necessarily have to • Summer salary corresponds to how much you are paid in the summer • Need to plan out budget year so fulfill commitments

Commitment = Payroll (Salary) Many Federal agencies allow differences between commitment and actual effort to be 25% (commit 10% only work 8%) Check terms and conditions of award But can’t change scope or specific aim Larger change? Need to get agency approval Personnel: Faculty

Effort Commitments: Committed Effort % Actual Effort % % Change in Effort Committed Effort % If more than 25% than have to ask permission from sponsor for reduction of committed effort “prior approval”

Effort Commitments: Commit 50% Charge 20% Commit 50% Charge 20% 60% Change in Effort Commit 50% If more than 25% than have to ask permission from sponsor for reduction of committed effort “prior approval”

Effort Commitments: Commit 25% Charge 20% 20% Change in Effort Commit 25% If more than 25% than have to ask permission from sponsor for reduction of committed effort “prior approval”

Commitment = payroll (salary) = effort Personnel Effort Reporting is required to document effort spent on sponsored project Certify % of effort spent on project Typically corresponds to % of salary Effort Reporting

Effort certification • ERS system • Happens 3 times a year • Required for all personnel who are paid from a grant • Acts like a receipt • All faculty certify their own • PI certifies everyone else (in grant)

Audit FormulaCommitment = Payroll = Effort • Committed Effort (for budget year) = • Salary Charged (over budget year) = (within 25% of effort committed) • ERS System: Certify Actual Effort Certified (for semester worked) (% charged = certified effort + 5% Total Effort)

No more than 50% time allowed (20 hours a week) Requirements for tuition waiver Requirements for health care Hiring from outside your department/consultation with home department Personnel: Graduate Students

Hiring new staff Named in grant can immediately hire Sponsored funded positions (employment only and until have funds) Vacation time terminates at end of grant Expedited procedure; if use approved positions described on URSA’s website (and HR’s website) Personnel : Staff

Advertising positions: new procedures Personnel Action Form (PAF) Interviewing 3 people Completion of interview forms HR/AA paperwork and review Background checks Approval to offer position Personnel : Staff

Someone who is contributing expertise to project Hourly, daily, or flat fee Travel/expenses can be paid as part of consultant payment or separately Cannot be a GSU employee or Co-PI on grant Federal grants can’t pay Federal employees State of GA employees & University system need to use different consultant agreements. Need to obtain permission Consultants

Postdoctoral Appointees • Policy and procedures • Expedited procedure • Don’t have to interview or post position • Can be a Postdoc Associate (hired as staff with fringe benefits) • Or, Fellows who are individuals with own funding paid as a stipend. Not paid GSU fringes

In general, GSU’s rules, regulations, and procedures govern non-sponsored expenses , govern sponsored projects Finance and Administration divisions. Forms and procedures: www.gsu.edu/finance/forms.html Business managers/post-award administrators should help Paying expenses

Equipment is anything = $5,000 or more Also known as Capital Equipment Equipment belongs to GSU (not you or, typically, agency) State contracting (preferred vendors) Sole source bids Tax exempt form on Finance - Business Services Supplies/Equipment

Participant support costs are those costs paid to (or on behalf of) participants in meetings, conferences, symposia, and workshops Registration fees, travel allowances, manuals and supplies, tuition, and stipends (no F&A charges) Subject fees are payments made to human subjects who are participating in your research to compensate them for their time Cash or gift cards. Refer to URSA Website Participant Costs vs Subject Fees

Grants Management