Post-Award Process - Office of Research

Report
GRANTS: CRADLE TO GRAVE
ALUMNI CENTER
BALLROOM
MAY 6, 2014
Post Award Processes
&
Effort Reporting
Roberta McManus
Associate Director – Sponsored Research Administration
2
Agenda
• Post Award Activities
• Principal Investigator's (PI) Responsibilities
• Compliance Regulations
• Key Financial SR Policies
• Budget & Expenditure Monitoring
• SRAS Review of Expenditures
• Collaboration with Other Researchers
• OMNI Overview
• PI Resources
3
Post Award Activities
• Award documents have been executed
 Signed by appropriate institution authority
• Award is to FSU, not the PI
• Proposal and Award number
• Project number assigned – budget activated!
 Cost sharing accounting
• Research can begin
 Adhere to scope of work
 Collaboration/subcontracting to other individuals/institutions
• Monitoring of activities - documentation
 Status reports
 Technical reports
• Payments will be held if not submitted timely
• Hold up future awards!!
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Post Award Activities
 Spending occurs
 Plan ahead to meet deadlines
 Personnel – Human Resources policies and procedures
 Non Personnel – Purchasing/Travel/Subcontract/Non PO
policies and procedures
 Sponsored Research Accounting Coordinators review
allowability of most (not all) expenditures
 Billing/Collecting from agencies (SRA responsibility)
 Financial reporting to agencies (SRA responsibility)
 Amendments (SOW & Budgetary)
 Contracting Officer for grantor and grantee
 Starts with Award Administrator
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Post Award Activities
• 90 days prior to award end
New funding increment?
Request extension if needed/allowed
Notify university grants officer in accordance with
timelines established
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Principal Investigator (PI) Responsibilities
• Understand agency rules/guidelines/restrictions
• Conduct work timely/professionally
• Comply with terms & conditions of award
• Ensure expenditures benefit the project and are in
compliance with award
• Monitor budget vs. expenditure over life of project
• Ensuring commitments are met including cost share
requirements
 Obligations in proposal and/or award documents
• 2 months of PI’s effort for academic term
• 15% of PI’s time for fall semester
 Must be met whether paid from award or not
• Monitor subcontractor performance
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Award Closeout
• SOW complete and final reports submitted
• Expenditures are complete:
 All charges incurred during project period are posted
 Avoid late cost transfers
 Charges posted allowable
 Necessary and benefit the award
• Subcontractor
 SOW complete
 Final invoice processed timely
• Effort reported for amount of time expended on project
• Commitments met
 Funded or not funded by award
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Compliance Requirements
• Federal
 New Federal guidance issued December 2013
 Effective for awards/increments issues on/after December 26,
2014
 OMB Circulars applicable to University
• A-21 (more on this later!)
• A-110
• A-133
• Available on SR website at:
http://www.research.fsu.edu/sras/complianceresources.html
 Agency specific requirements
 Terms and Conditions of award
• Non Federal
 Terms and Conditions rule!!
• FSU SR Related Policies and Procedures
 http://www.research.fsu.edu/contractsgrants/policypro.html#
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OMB Circular A-21
• SRS/SRAS use this resource daily
• Allowable 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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OMB Circular A-21
• Cost Accounting Standards (CAS)
• Selected Cost Items (Section J)
 54 types of expenses and whether allowable vs. unallowable
• Any 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 overruns
 Avoiding restrictions imposed by law or terms
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SR Financial Policies/Procedures
• Advances
• Cost Accounting Standards (CAS)
• Cost Sharing
• Cost Transfers
• Effort Commitments
• Fixed Price Residual Funds
• Indirect Cost Recovery
• Participant Support Costs
• Program Income
• Subrecipient Monitoring
• Unallowable Costs
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Advance Policy
• Ensure timely start up or uninterrupted continuation effort
prior to having a fully executed award document
• Criteria
• Written/verbal assurance from sponsor
• Delays would adversely impact the program or increase costs
• Department assumes risk by financially backing the direct cost
amount to be advanced
• No 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 source
• Transfers will not be approved
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Cost Transfer Policy
• Ensure that funds are properly managed
• Indicators of inadequate fiscal monitoring
Frequent cost transfers
Late cost transfers
Inadequately documented or justified cost transfers
• Examples of improper/unallowable cost transfers
Utilizing unexpended funds
Moving overrun on one project to another project
Moving unallowable costs on one project to another project
Circumventing award restrictions
Reimbursing a temporary “loan” of funds from another
project
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Cost Transfer Policy
• Proper cost transfers
The transfer represents an adjustment for an erroneous
charge
Split purchase
• Timeliness
Essential to evidence sound fiscal management
Monthly reconciliations!!!!!
• Policy
Payroll/Non Payroll
• Within 90 days of end of the month in which error occurred OR
• Within 30 days of the project expiration date
• Must complete Cost Transfer Justification Form
• SRA Cost Transfer Committee
Assistant Director –SRA Accounting Chairs
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Cost Accounting Standards (CAS)
• FSU is required to disclose “costing practices” in a
formalized document (Disclosure Statement-2)
• Describes how FSU treats
 Direct
 F&A costs
• Facilities
• Administration
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CAS – F&A Costs
• Examples of Costs that are normally treated as F&A:
• Administrative and Clerical Salaries
• Postage
• Local Telephone
• Office Supplies
• Data Processing/Computer Supplies
• General Purpose Software
• Memberships
• Subscriptions
• Cannot charge administrative and clerical expenses
directly to a sponsored project unless there are
exceptional circumstances
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CAS Exception Process
• Must be documented for all federally-funded awards
• Pertains to direct charge costs that are normally treated as
indirect costs
 Personnel
 Non-personnel
• Inclusion in the budget in the award document does not
automatically grant the exception
• Form at
http://www.research.fsu.edu/contractsgrants/forms.html
• Justify exceptional circumstance
• Submit to Sponsored Research Administration
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Cost Sharing
• Policy at
http://www.research.fsu.edu/contractsgrants/costs
haring.html
• Procedures at
http://www.research.fsu.edu/contractsgrants/docu
ments/csprocedures.pdf
• Definition = Costs not borne by FSU
• Criteria for tracking/reporting
Committed – Mandatory vs. Voluntary Committed
 Must account for and report
“Project Enhancement”
 Do not have to account for and report
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Cost Sharing
• Include in the proposal budget
 Cost Share Commitment Form
 Signed by Chair/Dean/Director
• Cost Share budgets are set up in OMNI
 Sponsored award/cost share budget set up same time
 Important to get cost share info to SRA or will hold up being
able to spend
• Does not include 3rd party
• Transfer cash when using these funding sources:
 PI Support projects
 SRAD projects
 FSU Foundation
 FSU Research Foundation
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Effort Certification
• Effort = Amount of time expended on a particular activity
• Federal government expects Universities to
 Meet commitments of time by key personnel (PI/CO-PI)
 Provide evidence that commitments have been met
• Requires periodic reporting by faculty and other staff
working on sponsored projects
• Application = 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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Budget & Expenditure Monitoring
• Award is to the University…however
• PI responsible for ensuring expenditures benefit the project
 Timing of when personnel need to be appointed
 Timing of when supplies will be used
 Collaboration with subcontractor in accordance with SOW
• Periodic budget vs. actuals reports (OMNI)
 Ensure anticipated expenditures charged
 Review for expenditures that do not belong on project
 Rate of expenditures reasonable for pace of research progress
Expect/Request expenditure reports
 Personnel – staff charged/encumbered
 Non-personnel
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SRA Review of Expenditures
• Requisitions > $1,000
• Travel and Expense reports > $1,000
• Unencumbered expenses (pay requests/participant
requests) >$1,000
• All personnel appointments
 Payroll cost transfers (Retroactive Distribution of Funding – RDF)
 Cost Transfer Justification Form
• All journal entries
 Cost Transfer Justification Form
• All interdepartmental requisitions
 Sales between departments (stockrooms, machine time, etc.)
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SRA Review of Expenditures
• Compliance Evaluation Criteria
Authorized Signature
• Sponsored Project Manager or PI
Chartfield Information
• DeptID, Fund Code, Project Combination
Performance Period
• Goods or Services received and consumed within
begin/end dates of award
• Available Balance
Direct cost budget check
• Budget category line item
• FDP/RTC
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SRA Review of Expenditures
• Account or Job Code
Appropriate for nature of expense
• Allowable
Remember OMB Circular A-21!
Terms and Conditions support expense
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Collaboration with Other Researcher
• Often included in proposal
 Institution approval vs. researcher
• Participates in research (sub recipient) vs. provider of
goods/services (vendor)
• Starts with SRA Subcontract Coordinator
• Standard agreement
 Incorporates Federal requirements
• Encumbered in OMNI as PO
 Numbers = RXXXX
• PI approves invoices (deliverables met)
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OMNI Overview
• Financial/Human Resource Systems
• Project financial information
Job Aids on Division of Sponsored Research at
http://www.research.fsu.edu/contractsgrants/
•
•
•
•
Available project balance inquiry
Generating project financial report
Running query of project expenditure detail
Generating HR report of payroll detail
Budget check against direct cost budget
Expenditures (costs incurred)
Encumbrances (POs, T-Auths, personnel appointments)
Not encumbered (future personnel appointments, tuition,
rent, F&A)
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PI Resources
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Training Opportunities
• CReATE – Compliance and Research
Administration Training and Education
Next session Fall 2014
New Federal guidance
• SRA Certificate Series
Curriculum geared toward support staff
Hands on tools
Summer schedule in process
Schedule posted at
http://www.research.fsu.edu/contractsgrants/workshops.html
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Web 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 Procedures
Forms
Funding Resources
OMNI Information
Training Information
Email/Newsletter Services (recommend getting on these list
serves)
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Web Resources
• Controller’s Office (http://www.vpfa.fsu.edu/control/)
General Accounting
Payroll Services
Property Accounting
Accounts Payable
Travel
• Office of Graduate Studies (http://gradstudies.fsu.edu/)
Matriculation Waiver Information
• Purchasing (http://www.purchasing.fsu.edu/)
• Human Resources (http://hr.fsu.edu/)
• OMNI Resources (http://erp.fsu.edu/OMNI-Training)
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Contact Information
SRA Assignment Sheet
http://www.research.fsu.edu/contractsgrants/documents/sta
ff.pdf
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QUESTIONS

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