Presentations text content in Grants: cradle to grave
Slide1
Grants: cradle to gravealumni CenterballroomMay 6, 2014
Post Award Processes
&
Effort Reporting
Roberta McManusAssociate Director – Sponsored Research Administration
Slide2Agenda
Post Award ActivitiesPrincipal Investigator's (PI) ResponsibilitiesCompliance RegulationsKey Financial SR PoliciesBudget & Expenditure MonitoringSRAS Review of ExpendituresCollaboration with Other ResearchersOMNI OverviewPI Resources
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Slide3Post Award Activities
Award documents have been executedSigned by appropriate institution authorityAward is to FSU, not the PIProposal and Award numberProject number assigned – budget activated!Cost sharing accountingResearch can beginAdhere to scope of workCollaboration/subcontracting to other individuals/institutionsMonitoring of activities - documentationStatus reportsTechnical reportsPayments will be held if not submitted timelyHold up future awards!!
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Slide4Post Award Activities
Spending occursPlan ahead to meet deadlinesPersonnel – Human Resources policies and proceduresNon Personnel – Purchasing/Travel/Subcontract/Non PO policies and proceduresSponsored Research Accounting Coordinators review allowability of most (not all) expendituresBilling/Collecting from agencies (SRA responsibility)Financial reporting to agencies (SRA responsibility)Amendments (SOW & Budgetary)Contracting Officer for grantor and granteeStarts with Award Administrator
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Slide5Post Award Activities
90 days prior to award endNew funding increment?Request extension if needed/allowedNotify university grants officer in accordance with timelines established
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Slide6Principal Investigator (PI) Responsibilities
Understand agency rules/guidelines/restrictionsConduct work timely/professionallyComply with terms & conditions of awardEnsure expenditures benefit the project and are in compliance with awardMonitor budget vs. expenditure over life of projectEnsuring commitments are met including cost share requirementsObligations in proposal and/or award documents2 months of PI’s effort for academic term15% of PI’s time for fall semesterMust be met whether paid from award or notMonitor subcontractor performance
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Slide7Award Closeout
SOW complete and final reports submittedExpenditures are complete:All charges incurred during project period are postedAvoid late cost transfersCharges posted allowableNecessary and benefit the awardSubcontractorSOW completeFinal invoice processed timelyEffort reported for amount of time expended on projectCommitments metFunded or not funded by award
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Slide8Compliance Requirements
FederalNew Federal guidance issued December 2013Effective for awards/increments issues on/after December 26, 2014OMB Circulars applicable to UniversityA-21 (more on this later!)A-110 A-133Available on SR website at: http://www.research.fsu.edu/sras/complianceresources.htmlAgency specific requirementsTerms and Conditions of awardNon FederalTerms and Conditions rule!!FSU SR Related Policies and Procedureshttp://www.research.fsu.edu/contractsgrants/policypro.html#
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Slide9OMB Circular A-21
SRS/SRAS use this resource dailyAllowable means:Reasonable (prudent person)Allocable (relative benefits)Treatment is consistent (direct vs. indirect)Conforms to limitations or exclusions (e.g. salary caps)Direct costs“identified specifically with a particular sponsored project”Facilities & Administrative (F&A) costs“incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular sponsored projects”
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Slide10OMB Circular A-21
Cost Accounting Standards (CAS)Selected Cost Items (Section J)54 types of expenses and whether allowable vs. unallowableAny costs allocable to a particular sponsored agreement may not be shifted to any other sponsored agreements for the purpose of (Cost Transfer Policy)Convenience – includes charging a project while waiting for another project/budget to be set up (Advance Policy)Meeting deficiencies caused by overrunsAvoiding restrictions imposed by law or terms
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Slide11SR Financial Policies/Procedures
AdvancesCost Accounting Standards (CAS)Cost SharingCost TransfersEffort CommitmentsFixed Price Residual FundsIndirect Cost RecoveryParticipant Support CostsProgram IncomeSubrecipient MonitoringUnallowable Costs
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Slide12Advance Policy
Ensure timely start up or uninterrupted continuation effort prior to having a fully executed award documentCriteriaWritten/verbal assurance from sponsorDelays would adversely impact the program or increase costsDepartment assumes risk by financially backing the direct cost amount to be advancedNo work is to be initiated until authorized by SRA (as evidenced by a project budget)DO NOT charge expenses for pending award to another funding sourceTransfers will not be approved
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Slide13Cost Transfer Policy
Ensure that funds are properly managedIndicators of inadequate fiscal monitoringFrequent cost transfersLate cost transfersInadequately documented or justified cost transfersExamples of improper/unallowable cost transfersUtilizing unexpended fundsMoving overrun on one project to another projectMoving unallowable costs on one project to another projectCircumventing award restrictionsReimbursing a temporary “loan” of funds from another project
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Slide14Cost Transfer Policy
Proper cost transfersThe transfer represents an adjustment for an erroneous chargeSplit purchaseTimeliness Essential to evidence sound fiscal managementMonthly reconciliations!!!!!PolicyPayroll/Non PayrollWithin 90 days of end of the month in which error occurred ORWithin 30 days of the project expiration dateMust complete Cost Transfer Justification FormSRA Cost Transfer CommitteeAssistant Director –SRA Accounting Chairs
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Slide15Cost Accounting Standards (CAS)
FSU is required to disclose “costing practices” in a formalized document (Disclosure Statement-2)Describes how FSU treatsDirectF&A costsFacilitiesAdministration
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Slide16CAS – F&A Costs
Examples of Costs that are normally treated as F&A:Administrative and Clerical SalariesPostageLocal TelephoneOffice SuppliesData Processing/Computer SuppliesGeneral Purpose SoftwareMembershipsSubscriptionsCannot charge administrative and clerical expenses directly to a sponsored project unless there are exceptional circumstances
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Slide17CAS Exception Process
Must be documented for all federally-funded awardsPertains to direct charge costs that are normally treated as indirect costsPersonnelNon-personnelInclusion in the budget in the award document does not automatically grant the exceptionForm at http://www.research.fsu.edu/contractsgrants/forms.htmlJustify exceptional circumstanceSubmit to Sponsored Research Administration
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Slide18Cost Sharing
Policy at http://www.research.fsu.edu/contractsgrants/costsharing.html Procedures at http://www.research.fsu.edu/contractsgrants/documents/csprocedures.pdf Definition = Costs not borne by FSUCriteria for tracking/reportingCommitted – Mandatory vs. Voluntary CommittedMust account for and report“Project Enhancement”Do not have to account for and report
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Slide19Cost Sharing
Include in the proposal budgetCost Share Commitment FormSigned by Chair/Dean/DirectorCost Share budgets are set up in OMNISponsored award/cost share budget set up same timeImportant to get cost share info to SRA or will hold up being able to spendDoes not include 3rd partyTransfer cash when using these funding sources:PI Support projectsSRAD projectsFSU FoundationFSU Research Foundation
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Slide20Effort Certification
Effort = Amount of time expended on a particular activityFederal government expects Universities toMeet commitments of time by key personnel (PI/CO-PI)Provide evidence that commitments have been metRequires periodic reporting by faculty and other staff working on sponsored projectsApplication = Faculty Assignments Effort Certification Tracking (FACET)After each academic term (Fall, Spring, Summer) for Exempt (PIs)Monthly for Non-exempt employees (OPS – temporary)Provide reasonable estimates of time/effort spent on various activities (instruction, advising, projects, etc.)
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Slide21Budget & Expenditure Monitoring
Award is to the University…howeverPI responsible for ensuring expenditures benefit the projectTiming of when personnel need to be appointedTiming of when supplies will be usedCollaboration with subcontractor in accordance with SOWPeriodic budget vs. actuals reports (OMNI)Ensure anticipated expenditures chargedReview for expenditures that do not belong on projectRate of expenditures reasonable for pace of research progressExpect/Request expenditure reportsPersonnel – staff charged/encumberedNon-personnel
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Slide22SRA Review of Expenditures
Requisitions > $1,000Travel and Expense reports > $1,000Unencumbered expenses (pay requests/participant requests) >$1,000All personnel appointmentsPayroll cost transfers (Retroactive Distribution of Funding – RDF) Cost Transfer Justification FormAll journal entriesCost Transfer Justification FormAll interdepartmental requisitionsSales between departments (stockrooms, machine time, etc.)
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Slide23SRA Review of Expenditures
Compliance Evaluation Criteria Authorized SignatureSponsored Project Manager or PIChartfield InformationDeptID, Fund Code, Project CombinationPerformance PeriodGoods or Services received and consumed within begin/end dates of awardAvailable BalanceDirect cost budget checkBudget category line itemFDP/RTC
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Slide24SRA Review of Expenditures
Account or Job CodeAppropriate for nature of expenseAllowableRemember OMB Circular A-21!Terms and Conditions support expense
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Slide25Collaboration with Other Researcher
Often included in proposalInstitution approval vs. researcherParticipates in research (sub recipient) vs. provider of goods/services (vendor)Starts with SRA Subcontract CoordinatorStandard agreementIncorporates Federal requirementsEncumbered in OMNI as PO Numbers = RXXXXPI approves invoices (deliverables met)
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Slide26OMNI Overview
Financial/Human Resource SystemsProject financial informationJob Aids on Division of Sponsored Research at http://www.research.fsu.edu/contractsgrants/Available project balance inquiryGenerating project financial reportRunning query of project expenditure detailGenerating HR report of payroll detailBudget check against direct cost budgetExpenditures (costs incurred)Encumbrances (POs, T-Auths, personnel appointments)Not encumbered (future personnel appointments, tuition, rent, F&A)
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Slide27PI Resources
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Slide28Training Opportunities
CReATE – Compliance and Research Administration Training and EducationNext session Fall 2014New Federal guidanceSRA Certificate SeriesCurriculum geared toward support staff Hands on toolsSummer schedule in processSchedule posted at http://www.research.fsu.edu/contractsgrants/workshops.html
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Slide29Web Resources
Office of Research (http://www.research.fsu.edu/)Division of Sponsored Research (http://www.research.fsu.edu/contractsgrants/index.html)Staff Contact Information (SRAS assignments attached)Policies and ProceduresFormsFunding ResourcesOMNI InformationTraining InformationEmail/Newsletter Services (recommend getting on these list serves)
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Slide30Web Resources
Controller’s Office (http://www.vpfa.fsu.edu/control/)General AccountingPayroll ServicesProperty AccountingAccounts PayableTravelOffice of Graduate Studies (http://gradstudies.fsu.edu/)Matriculation Waiver InformationPurchasing (http://www.purchasing.fsu.edu/)Human Resources (http://hr.fsu.edu/) OMNI Resources (http://erp.fsu.edu/OMNI-Training)
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Slide31Contact Information
SRA Assignment Sheet http://www.research.fsu.edu/contractsgrants/documents/staff.pdf
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Slide32QUESTIONS
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Grants: cradle to grave
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