Transcript Project Management for Sponsored Projects

Post Award Processes and
Effort Reporting
Roberta McManus
[email protected]
645-2485
Today’s Agenda
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What is Post Award?
What are the PI’s Responsibilities?
What are Compliance Requirements?
I am a researcher why do I have to approve
expenditures and monitor budgets?
 SRAS Review of Expenditures
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Advance Policy
Cost Transfer Policy
CAS Exemptions
What is cost sharing?
What is Effort Reporting
 OMNI Overview
 PI Resources
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What is Post Award?
Activities that occur after award documents have been
executed by appropriate institution authority
 Award is to FSU, not the PI
 Project number assigned
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Cost sharing accounting
 Research can begin
 Adhere to scope of work
 Collaboration/subcontracting to other individuals/institutions
 Status reports
 Technical reports
NOTE some invoices require submission prior to
payment
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What is Post Award?
 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 Services (SRAS) review
allowability of most (not all) expenditures
 Billing/Collecting from agencies (SRAS responsibility)
 Financial reporting to agencies (SRAS responsibility)
 Amendments (SOW & Budgetary)
 Contracting Officer for grantor and grantee
 Starts with Pre Award Administrator
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What are the PI’s 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
 Monitor subcontractor performance
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What are Compliance Requirements?
 Federal
 OMB Circulars applicable to University
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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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What are Compliance Requirements?
 Hot button issues frequently cited in audits
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Cost transfers onto or between projects – do it
right the first time!
Expenditures late in the project – using up
available balance
Cost share accounting/reporting
Effort reporting processes
Charging costs normally considered overhead
directly to projects
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OMB Circular A-21
 SRS/SRAS use this resource daily
 Allowable means:
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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)
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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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Sponsored Research 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
 Sub recipient Monitoring
 Unallowable Costs
 Closeout Authority – Memorandum dated September 24, 2008
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How do I collaborate with another
researcher?
 Often included in proposal
 Institution approval vs. researcher
 Participates in research (sub recipient) vs.
provider of goods/services (vendor)
 Starts with SRS Subcontract Coordinator
 Standard agreement
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Incorporates Federal requirements
 Encumbered in OMNI as PO
 Numbers = RXXXX
 PI approves invoices (deliverables met)
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Why do I approve expenditures and
monitor budgets?
 Award is to the University…however
 PI responsible for ensuring expenditures benefit
the project
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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
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SRAS Review of Expenditures
 Transactions SRAS Coordinators evaluate
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Requisitions > $1,000
Travel and Expense reports > $1,000
Unencumbered expenses (pay
requests/stipends)
All personnel appointments
All journal entries
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Cost Transfer Justification Form
All interdepartmental requisitions
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SRAS Review of Expenditures
 Compliance Evaluation Criteria
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Authorized Signature
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Chartfield Information
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Sponsored Project Manager or PI
DeptID, Fund Code, Project Combination
Performance Period
 Goods or Services received and consumed within Dates of Award
period
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Available Balance
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Account or Job Code
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Direct Cost Funds available for Expense by budget category line
item
Appropriate for nature of expense
Allowable
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Remember OMB Circular A-21!
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Terms and Conditions support
expense
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Advance Policy
 Purpose: Ensure timely start up or uninterrupted
continuation effort prior to having a fully executed award
document
 Criteria
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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 SRS (as
evidenced by a project budget)
 DO NOT charge expenses for pending award to another
funding source
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Transfers will not be approved
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Cost Transfer Policy
 Purpose: 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
 Avoiding/alleviating an over expenditure
 Moving unallowable costs on one project to another
 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 of identification and correction of errors is
essential to evidence sound fiscal management
 Policy
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Payroll/Non Payroll
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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
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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
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Direct
F&A costs
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Facilities
Administration
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CAS – F&A Costs
 Examples of Costs that are normally treated as F&A:
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Administrative and Clerical Salaries
Postage
Local Telephone
Office Supplies
Data Processing/Computer Supplies
General Purpose Software
Memberships
Subscriptions
 Cannot charge expenses typically treated as an
indirect cost 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
 Inclusion in the budget in the award document
does not automatically grant the exception
 Form at
http://www.research.fsu.edu/contractsgrants/form
s.html
 Submit to Director, Sponsored Research
Services
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What is Cost Sharing?
 Policy at
http://www.research.fsu.edu/contractsgrants/
costsharing.html
 Definition = Costs borne by FSU
 Criteria for tracking/reporting
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Committed—Mandatory vs. Voluntary Committed
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Must account for and report
“Project Enhancement”
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Do not have to account for and report
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What is 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
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Important to get cost share info to SRS or will hold
up being able to spend
Does not include 3rd party
Transfer the cash for PI, SRAD, Auxiliary, FSU
Fdtn, Research Fdtn funding sources
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What is Effort Reporting?
 Federal government expects Universities to
 Meet commitments
 Provide evidence that commitments have
been met
 FSU certification cycle
 Certify after each academic term
 Application = Faculty Assignments effort
Certification Tracking (FACET)
 Provide reasonable estimate of time spent on
various activities (instruction, advising,
projects, etc.)
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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/
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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
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Next session May 17 & 18
 Lunch & Learn series
 1-2 per month
 Wednesdays 11:30am – 12:30pm
 Current schedule
http://www.research.fsu.edu/contractsgrants/worksho
ps.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
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(http://www.vpfa.fsu.edu/control/)
General Accounting
Payroll Services
Property Accounting
Accounts Payable
Travel
 Office of Graduate Studies (http://gradstudies.fsu.edu/)
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Tuition 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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QUESTIONS
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