WU is required by federal policies to monitor purchases They should be allocable benefit the project allowable per institutional and federal guidelines and consistent ly treated within WU ID: 630993
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Slide1
Justifications Why are justifications needed?
WU is required by federal policies to monitor purchases. They should be
allocable
(benefit the project),
allowable
(per institutional and federal guidelines) and
consistent
ly treated (within WU).Slide2
More justification is required for federal grants than foundations or for internal fundingSPA is familiar with lab research, but not necessarily human studies research
Pediatrics has more strict internal procedures for certain purchases
New policies will be disseminated
and posted soon
How items are classified (budget-object codes) tells accounting how much review and justification is required. Some typical items that require more review/justification are:
General Supplies
Entertainment Services
Social Purchases
Sponsored Project Events
Equipment over $5K
Electronic Devices
Purchases at the end of the grant
periodSlide3
Justifications are written on check request forms or in the comments section of Marketplace ordersSome items require a special approval by SPA via an ACE (Administrative Cost Exception) form. This form is to show the unique and unlike circumstances of the award to pay for items such as:
Admin/Clerical Salaries
Research Office Supplies
Laser Printer Supplies
Postage
Local Telephone/Cell Phones
Data Lines
Memberships/Subscriptions
Some items will never be approved, no matter how well justified they are, based on standard
allowability
guidelines set in place by WU or the federal governmentSlide4
Each purchase should be items/services needed to benefit the aims presented in the research.
Items presented in the budget are not automatically approved and allowable
Justifications need to be entered for each purchase.
Each purchase
(CR/PO/TR,
etc
) needs to be able to be viewed as a stand-alone document for auditing purposes. It cannot refer back to another purchase.
Consistent unique circumstances need to be identified and standard approved language can be worked out with SPA by administration.Slide5
A justification is an explanation of the reasons why the grant should pay for this product/service.
How
does this support the aims of the project
?
What
value does this item provide to the science
?
Where
will the services be performed
?
Why
is this item beneficial to the science?Slide6
Helpful hints:Blind them with science
!
Do
not
purchase items before submission to accounting.
They
might not be approved!
Often
the
budget justification from your submission has the info needed.
Work with your administrator if you’re not sure how to handle/answer. We can advise!Slide7
Gift Cards Introduction
Currently
, we have two methods for procuring gift cards to use as study reimbursements:
T
he
TA/
TR
method
(
Travel Advance/Travel Report
)The Marketplace method Slide8Slide9
Forms and Their PurposeTA - Travel Advance
TR
- Travel Report
PO - Purchase order via MarketplaceSlide10
TA (Travel Advance)
Designed to put funds in your personal account for use when traveling for WU business
The purpose has been altered to put funds in your personal account for use in purchasing gift cards, etc. for participant incentives
The amount requested for incentives should be for approximately one month’s worth
Time frame
Funds are deposited within a few days to the employee’s personal account
This method is good for tracking incentives for accounting
This method puts the responsibility on the individual to purchase the incentivesSlide11
TR (Travel Report)
This form is completed when all patient incentives have been distributed and
reconciles (closes)
the open Travel AdvanceSlide12
PO (Purchase Order) via Marketplace
Coordinator can place a Marketplace order with various companies to request gift cards
Typically, a form from the company must be completed to show the specific incentives needed.
This form will accompany the check cut by WU to the company
Once the check is received (and cleared) by the company, they will send the gift cards
This method can take up to
two or three
weeks from start to finish
Time frame can be extended if vendor does not have
the specific requested cards
in stock
This method requires no fiscal purchase responsibility for the individualThis method requires forecasting and planning in order to not run out of incentivesSlide13
New Gift Card Process
Tracking gift card purchases
Sending proper information to the Tax Dept.
New audit process (to comply with new policy)Slide14
Purpose of the new policyTo document proper management of patient incentives and ensure the proper handling and distribution for purposes of subject reimbursement.
This
includes providing segregation of duties, documenting all payment, and ensuring proper reconciliation. Slide15Slide16
Procedures for Logging Gift Cards for Study Participation1. Coordinators will record all required information on the “Log of Payment by Cash or Gift Card for Study Participation” (Excel log attached). Other forms for reporting this information will not be accepted. There should only be 1 document number (TA/PO#) per log.
2. Once all cash/gift cards per TA/PO are distributed, send the completed log to
Linda_Kennedy@wustl.edu
in the tax department and CC your PA (purchasing assistant).
3. Because the form contains sensitive personal data the log
MUST
be password protected when sending the log to the tax department. Use password “
Pediatrics
” every time you send a spreadsheet. 4. Email the log to the tax department within 15 days after all gift cards/cash purchased on a TA/PO have been distributed. In the event that all gift cards/cash haven’t been distributed by December 31, provide the tax department with the current log through December 31 and start a new log for the calendar year beginning January 1.5. Start a new log for each TA or PO upon sending a log to the tax department.6. The tax department considers all patient incentives (gift cards, meal tickets, toys or other items) as cash. Under IRS procedures WU is required to request the SSN for all participants that receive more than $10 in the aggregate for a calendar year as compensation for participation in a research study.7. In the event that a participant refuses to provide a SSN, enter “REFUSE” in the SSN box. Enter “FOREIGN” if the participant is a foreign national and does not have a SSN.
8. A receipt signed by the participant and the distributor should be obtained for each cash/gift card that is distributed and filed with the corresponding log.
9. Coordinator (person who requests the TA/PO) will keep a spreadsheet of all gift cards/currency denomination amounts and the name of the person that is handing out the gift card/cash to the participant. (see example spreadsheet)
10. All gift cards/cash will be stored in a locked cabinet or drawer at all times.
11. Random spot audits will be performed periodically to verify that:
- All information is being obtained by the participant
- The coordinator is logging all information accurately and sending the information to the tax
department
- To ensure that all gift cards/cash are accounted for and a receipt is provided for all gift cards/cash that is distributed.Slide17
Log that will be sent to the Tax Dept.Slide18
ExampleSlide19
Log of Gift Cards On HandSlide20
ExampleSlide21Slide22