Research Administration 102

1. Research Administration 102 Session 4: Award Management BonniejeanZitske, Managing Officer, Research and Sponsored Programs, bzitske@rsp.wisc.edu, 2-9727 Rebecca Bound, Research Administrator, College of Agricultural & Life Sciences Research Division rbound@cals.wisc.edu 5-8443 December 7, 2011

2. Overview • What is Award Management? • Lifecycle of Sponsored Projects • Roles and Responsibilities • OMB Circulars: A-21, A-110, A-133 • FDP/Expanded Authorities • Effort reporting • Subawards • Cost sharing • Cost Transfers 10. Cash management 11. Closeout and audits 12. Audits 13. Best practices 14. Tools 15. What if I have questions

3. 1. What is Award Management? Day-to-day activities to assure compliance with award requirements (terms/conditions), from the receipt of the award through close out and beyond. (Beyond the award includes such aspects as records retention, property control, audit activities.)

4. 1. What is Award Management? Why is responsible award management important? Maintains relationship of trust between sponsors, institution and public (stewardship), and reputation with colleagues Future awards depend on it Audit findings and cost disallowances Criminal, civil and administrative penalties (compliance)

5. 2. Lifecycle of Sponsored Projects Sponsor Accepts Or Rejects Proposal Preparation Proposal Review Award Management (and Project Performance) Award Negotiation and Acceptance Award Established Technical and Fiscal Closeout Roles and Responsibilities

6. 3. Roles and Responsibilities Responsibilities are shared by: • Principal Investigators • Departments/Center staff • School/College Dean’s Office • Research and Sponsored Programs It is important that all of the parties who share some of the responsibility work as a team.

7. 3. Roles and Responsibilities Roles and Responsibilities Matrix on RSP website: http://www.rsp.wisc.edu/policies/staffroles.html Note that specifics vary between departments and divisions on campus, but you can refer to this for general guidelines and talk to your school/college research administrator for more detail regarding expectations for your unit.

8. 3. Roles and Responsibilities Expectation of Departments/Centers: Knowledge of the terms/conditions of award and applicable University/State policies Assist PI with overall award management Review requests and supporting documentation for adequacy as well as allocability, allowability, reasonableness, applicability Prepare paperwork, process transactions/adjustments in a timely manner, and secure authorized signatures Submit/forward paperwork/transactions to appropriate Divisions for review, approval, and action

9. 3. Roles and Responsibilities Expectations of Departments/Centers (continued): Verify fund availability and conduct periodic financial reconciliations (with projection reports to Pis) Assure compliance with award terms/conditions andUniversity/State policies Initiate close-out – contact RSP in a timely manner

10. 3. Roles and Responsibilities Expectations of Departments/Centers: If you are uncertain, ask (Don’t send through something if you are not sure whether it is allowable/acceptable expecting someone else to catch it) Look out for the interests of your investigators, but also help them to understand the need for compliance, and the shared responsibilities across campus

11. 3. Roles and Responsibilities Important reminders regarding roles and responsibilities: Applications are submitted by the University of Wisconsin-Madison on behalf of the Principal Investigator Research and Sponsored Programs is delegated signature authority (authorized official) by the Board of Regents for proposals, agreements, contracts, etc. related to extramural support activities of the University Awards are accepted by the University and assigned to a Principal Investigator Principal Investigator is responsible and accountable to the grantee for the proper conduct of the project or activity

12. 3. Roles and Responsibilities Important reminders regarding roles and responsibilities (continued): Authorized official is held responsible by the sponsor to assure that the institution will meet the obligations Each of us is a representative of the UW, accountable to theState of Wisconsin, and ultimately responsible for assuringefforts of good stewardship

13. 4. OMB Circulars What are OMB Circulars? OMB is the Office of Management and Budget of the US Federal government. Circulars are instructions or information issued by OMB, and the circulars relevant to the University guide our processes, policies and systems for administration of federal funds.

14. 4. OMB Circulars Which OMB Circulars apply to the University? Circular A-21 addresses Cost Principles for Educational Institutions. Circular A-110 addresses Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations. Circular A-133 addresses Audits for States, Local Governments, and Non-profit Organizations.

15. 4. OMB Circulars Where can I find the Circulars? Available at the OMB website:http://www.whitehouse.gov/omb/circulars/ Mini guides available from NCURA*:https://www.ncura.edu/prev/store/ *NCURA = National Council of Universtiy Research Administrators

16. 4. OMB A-21 What is the purpose of OMB A-21? • Applies to grants, contracts, and other agreements with educational institutions • Principles established in A-21 are designed to provide that the Federal Government bears its fair share of total costs, determined in accordance with generally accepted accounting principles, except where restricted or prohibited by law

17. 4. OMB A-21 Requirements defined in A-21: Institutions must treat similar costs consistently as either Direct costs or F&A* costs. Certain types of costs will be included in the institution’s F&A cost rate and will not be charged as Direct costs to Federal projects. *F&A = Facilities and Administration = Indirect Costs

18. 4. OMB A-21 Costs are reimbursable by the Federal Government ONLY if they are: Necessary Reasonable Allocable Allowable Consistently treated Permissible See A-21 Section C.

19. 4. OMB A-21 Necessary Costs applied to the project MUST be necessary to accomplish the scope of work. To be necessary, the cost applied must be absolutely essential to achieve a certain result or results.

20. 4. OMB A-21 Reasonable If the nature of the goods or services acquired or applied to the project reflect the action that a “prudent person” would take under similar circumstances. Emphasis would be upon one acting in good judgment. Not excessive or extreme; fair.

21. 4. OMB A-21 Allocable Cost is incurred solely for advancement of work on the project. Application of cost is in proportions that can be approximated through reasonable methods. Cost is necessary and deemed assignable to the project.

22. 4. OMB A-21 Allowable Allowability of costs is defined specifically in OMB Circular A-21 Section J General Provisions of the cost principles. Note: Section J does not indicate whether the cost should be treated as a direct cost or F&A cost.

23. 4. OMB A-21 Consistently treated Like costs must be treated the same in like circumstances … consistently. Costs may be treated as direct costs only or as F&A costs only.

24. 4. OMB A-21 Permissible Costs must be permissible under the law AND Costs must be permissible under terms/conditions of the award

25. 4. OMB A-21 Costs normally treated as F&A costs: Administrative and Clerical Salaries Telecommunications -- Local Telephone ServiceIncluding phone equipment such as telephones, cell phones, pagers, fax machines, and line charges PostageIncluding U.S. Postal Service, Federal Express, UPS Office supplies Dues and memberships

26. 4. OMB A-21 Costs normally treated as F&A costs (continued): Subscriptions, Books, and Periodicals General Purpose EquipmentNon-research equipment which may be used for general office purposes such as desktop computers, laptop computers, printers, fax machines, copy machines, and office furniture. General computer services, networking costs, or other DoIT services Staff recruitment and relocation

27. 4. OMB A-21 When is a cost eligible as an Exception? A cost normally treated by UW-Madison as an F&A cost may be appropriate as a direct cost on a Federally sponsored project if: The cost is necessary, reasonable, allocable, allowable, and permissible under the law, terms/conditions of the award, and the circumstances are “unlike.” “Unlike” circumstances may be determined by the nature of the project, such as those detailedin Exhibit C of OMB Circular A-21.

28. 4. OMB A-21 Exception Review and Approval: Investigators should provide clear justification in Federal project budgets for direct cost items that normally are treated as F&A costs. The fact that the sponsoring agency allows such costs to remain in the awarded budget may not be interpreted as approval for these items as CAS exceptions. School/College Dean’s Offices review andapprove CAS exceptions on sponsoredproject budgets. This institutional approvalis required by A-21.

29. 4. OMB A-21 How does all of this apply to Non-Federal awards? General Principles of A-21 apply. -- More exceptions than on the Federal side. Many Non-Federal Sponsors prohibit direct charging of certain types of costs. Full Indirect Cost Recovery vs. Partial (or No) Recovery. Bottom Line: It Depends.

30. 4. OMB A-110 What is the purpose of OMB A-110? Sets forth standards for obtaining consistency and uniformityamong Federal agencies in the administration of grants to and agreements with institutions of higher education, hospitals, and other non-profit organizations Includes many pre-award, post-award and after the award requirements related primarily to institutional infrastructure (i.e., purchasing system, draw down of federal funds, etc.)

31. 4. OMB A-133 What is the purpose of OMB-133? Sets forth the standards for obtaining consistency and uniformity among federal agencies for the audit of state, local governments, and non-profit organizations expending federal awards. See the Legislative Audit Bureau’s website at http://www.legis.state.wi.us/lab/ for the State of (Auditor) Wisconsin Single Audit report.

32. 5. FDP/Expanded Authorities FDP = Federal Demonstration Partnership FDP is a cooperative initiative among federal agencies and institutional recipients of federal funds.  It was established to increase research productivity by streamlining the administrative process and minimizing the administrative burden on principal investigators while maintaining effective stewardship of federal funds.

33. 5. FDP/Expanded Authorities Expanded Authorities include: 90 day pre-spending authority institutionally approved no-cost extensions up to one additional year automatic carryover of unobligated funds from one budget period to the next Note: these do not apply to non-federally funded projects and even some federally funded projects are awarded without expanded authorities.

34. 5. FDP/Expanded Authorities Federal agencies do retain the right to override certain FDP general conditions with agency specific requirements. For general FDP terms/conditions: http://www.nsf.gov/home/grants/grants_fdp.htm RSP has provided grids of each agency's basic requirements as it relates to business at the UW-Madison. For NSF, NIH, UDSA, DOE, EPA:http://www.rsp.wisc.edu/awardmgt/fdpnondefense.html For AFOSR, ONR, Army Med, Army (ARO), NASA:http://www.rsp.wisc.edu/awardmgt/fdpdefense.html

35. Questions? 10 minute break

36. 7. Subawards Setting Up a Subagreementhttp://www.rsp.wisc.edu/awardmgt/subagmts.html Look for RSP to initiate subaward process If no word from RSP, send e-mail to: outgoingsubs@rsp.wisc.edu Documents needed to create a subaward: Subagreement budget Subagreement scope of work Subagreement Information Table completed in full Subaward Tracking Database https://www.rsp.wisc.edu/services/admin/sub_search.cfm

37. 7. Subawards Monitoring: Prime is responsible for conduct and completion of project Progress reports should be reviewed by PI Issue award funding in increments (e.g., yearly basis) to provide a check/balance opportunity to review progress/ performance, discuss issues, review expenditures Invoices should be reviewed and approved by PI F&A is charged on first $25K only (for awards calculated using MTDC); monitor to ensure this is charged correctly

38. 7. Subawards More on monitoring: Close-out can be a complication: some choose to end subawards early in the final year to assure sub has 90 days to close-out and prime also has 90 days to close-out Some choose to use modified language in award terms, reducing sub close-out period to 45 or 60 days, rather than the standard 90 days

39. 7. Incoming Subawards A few considerations on incoming subawards: Automatic carryover from one budget period to another does not generally apply Reports and invoices are submitted to the prime awardee, not the prime sponsor Payments are not handled through the draw-down process, even if the subaward is federally funded Watch end dates and deadlines carefully – we are more likely to have payment withheld for late reports and invoices on subawards than standard, direct awards

40. 8. Cost Sharing OMB Circular A-110 C.23 provides guidance in regard to satisfying Cost Sharing/Matching. Documentation of Cost Sharing/Matching is a responsibility of the PI (with assistance from Department/Center and School/College). Limit commitments if at all possible.

41. 8. Cost Sharing Cost sharing is subject to the same OMBrules as the sponsored project. Where effort is voluntarily committed on a project, staff effort must be entered in WISPER at time of award so commitments are carried forwarded as Cost Share in the campus Effort Reporting system (ECRT).

42. 9. Cost Transfers UW Cost Transfer Policy • It is the policy of the University of Wisconsin-Madison that costs should be charged to the appropriate sponsored project when first incurred. • The official policy can be found at both websites: • Research and Sponsored Programs • Business Services

43. 9. Cost Transfers What is a cost transfer? • Definition • A reallocation of a posted salary or non salary expense between established funding strings • Warning! • Cost transfer activity can be a warning flag to external auditors especially those who review grant administration

44. 9. Cost Transfers Why would I need a cost transfer? • Cost transfers are for correcting errors • Identify the problem -Incorrect entry -Over-spending -“Cost Sharing” • Allowability and allocability of costs must be established (sponsor guidelines, A-21) • Costs not allocable to a project cannot be transferred to that project, even temporarily

45. 9. Cost Transfers • Example of Acceptable Transfer • Correction of a clerical error • Reallocation of expenses where multiple accounts benefited • Reallocation of shared resource costs • Transfer of costs to divisional discretionary funds

46. 9. Cost Transfer 90 Day Justification • Why was this expense originally charged to the coding from which it is now being transferred? • Why should the charge(s) be transferred to the proposed receiving project (i.e., how does the project benefit)? • Why are the charges allowable and allocable based on the terms and conditions of the receiving award? • Why is this cost being transferred more than 90 days after the transaction occurred? • What corrective action has been taken to eliminate the need for cost transfers of this type in the future?

47. 9. Cost Transfers How can I avoid cost transfers? • Maintain accurate internal billing information • Example: MDS has the PAT tool • Review p-card edits each billing cycle • Be aware of staffing appointments, changes

48. 10. Cash Management Federal grants are funded via an institutional Letter of Credit, and cash management for these projects is handled by RSP. Departments/Centers should monitor cash receipts on non-federal projects. For cost reimbursable awards you’ll find this information in WISDM; for others cash balance is not yet shown, so please contact your RSP accountant.

49. 11. Closeout What is Closeout? Process to finalize all sponsor requirements at the conclusion of the award Each award will detail the requirements but typically these include: Final Technical (programmatic) Report Final Property Report Invention Report Final Fiscal (financial) Report

50. 11. Closeout Important points to remember: Standard timeline for completion of reconciliation and closeout is within 90 days of project end date. Must show cost sharing Must not show unpaid obligations Technical reports by PI – refer to terms/conditions for submission requirements Carefully review terms/conditions to determine the full compliment of closeout requirements (e.g., property report, data sharing) Closeout will be covered in more detail in the next Res. Admin 102 session