Transcript Grants Management for PIs - University Research Services

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
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
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
Notice of Award
Getting an Account Number
Terms & Conditions 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 Grant Award (NGA)
Letter
Check
Contract
PIs are not the “authorizing official” of GSU OR
GSURF
Can’t sign anything for University
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
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
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
Account numbers – code source of funding
Federal, state, nonprofit, and for-profit
Types of projects
Research, basic, and applied
Instruction
Other
Budget categories set up based on awarded
budget
“Funded” based on annual budget, even if
awarded 5 years
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
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
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
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
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
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
Expanded authorities allow request for oneyear 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
Expenditures
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
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
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
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
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
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
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
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
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
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”
Commit
Commit
50%
50%
Charge
20%
20%
Commit
50%
If more than 25% than have to ask permission from
sponsor for reduction of committed effort “prior approval”
60%
Change
in Effort
Commit
25%
Charge
20%
20%
Commit
25%
If more than 25% than have to ask permission from
sponsor for reduction of committed effort “prior
approval”
Change
in Effort
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
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)
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
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)
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
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
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
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
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
P’Cards are a method for making purchases
Training required (but training geared to use
with state funds; “allowable” not accurate for
sponsored projects)
Can only charge allowable direct costs
(especially scrutinized by auditors)
Further info:
www.gsu.edu/accounting/purchasing-pcard.html
Forms:
www.gsu.edu/accounting/purchasing-forms.html
Handout has a checklist to differentiate the
three ways people can be involved in a grant
Individuals who are contributing expertise to
the project
Must have a consulting agreement if payment
over $5,000
Step by step guide available:
www.gsu.edu/accounting/paymentcontrators-consultants.html
Formal Agreement between GSURF and other
institution
Subcontract typically have a PI
Terms & Conditions of award apply to
subcontract
Even if got institutional support letter during
proposal process, once awarded, need to set
up formal subcontract
If not part of original proposal, may have to go
back to the agency (depends on agency)
Complete request for subcontract form (OSP)
Need statement of work and budget for
subcontract
OSP will, then, use a standard subcontract
form and submit form to the OSP office of the
PI’s institution to be processed
Can only be for one year. Amended annually
by sending request for subcontract
If want own terms, PI must work with OSP and
Legal dept and then get final approval by Legal
dept
Invoices from subcontract
Responsible for certifying programmatic
aspects of subcontract
Did they do the expected work?
Responsible for certifying charges on invoice
Are they reasonable, valid, etc.?
Everyone, with fiscal responsibility, must
review summary of budget monthly
Spectrum (Peoplesoft) Drilldown Reports
Difference between budget year and fiscal year
Important to check what has been charged and
what has not been charged
Subcontract and consultant invoices (PI
responsible for ensuring work is completed
and expenses appropriate)
P-Card Activity Log needs to be reconciled with
VISA/Bill statement with receipts
Indirect Costs (F&A) not charged on participant
support costs, equipment, and subcontracts
above $25K
Very important expenses are “properly” coded
because F&A is collected based on expense
code
Cost Transfer: Movement of expense(s)
between two different university account
numbers
Charges should be moved within 90 days of
initial charge
Expenditure review should enable you to
catch errors
Charges moved after 90 days require PI’s
signature
No transfers, involving state funds, goes
beyond current fiscal year (July 1st)
Personnel charges can’t be changed over fiscal
years or overlap years
No transfers allowed to a sponsored account if
expense is more than a year old
When error was discovered
What the charge was for
Why the charge was incorrectly made
How it, specifically, relates to the sponsored
project account to which it will be transferred
Transfer costs on to a project:
1. Are charges Reasonable, Allowable,
Allocable, and consistently Treated?
2. Over 90 days requires justification and is a
“red flag” to auditors
3. Especially a problem if at end of the grant
4. Dubiously looks as if you are just spending
the money$$
Progress Reports
Final Report
Financial reports
PI responsible for the “technical” contents of
the report
If required, Research Financial Services will file
financial report or supply to you the financial
information; although you need to request for
report
Expenditures toward the end of the grant must
be reasonable
Cost transfers should be minimized
Everything needs to balance
The Federal government’s auditors are very
serious about institutions following the policies
Florida International paid $11.5 million in
fines
UAB paid $3.39 million
Northwestern $5.5 million
DHHS OIG Work Plan:
Effort Reporting
Commitments
 Was the Proposed Effort Met?
 Are Faculty Overcommitted?
Certification
 Was the Certifier appropriate?
 Account for “All” activities?
DHHS OIG Work Plan:
Effort Reporting
Allocability
 Are Payroll Adjustments Appropriate?
 Do Administrative & Clerical Salaries
Appear on Sponsored Projects?
Timeliness
 Why are there Delays in Certifying
Effort?
 Do Delays Indicate Bigger Issues?
DHHS OIG Work Plan:
Cost Transfers
 Was the “How & Why that Occurred”
documented?
 Are charges Reasonable, Allowable,
Allocable & consistently Treated?
 Did the PI “certify” the correctness of the
new charges to their sponsored project?
 Are processes changed to prevent future
cost transfers?
Minimize cost transfers and delays!!
Review Green Sheets for initial awards
 Check project dates
 Check project salary budget
 Update PAF as soon as possible –
minimize cost transfers
Complete Monthly Expenditure Review
Questions?