Transcript Slide 1

May 19, 2015Administrators
Workgroup
Agenda
 Introductions
 Announcements / Updates (Raquel Espinosa)
 NIH Cap in PeopleSoft (Anthony Cassese, Cora Cheng-Chong)
 Cost Transfers (Rena Huynh, Ayse Taciroglu)
 Effort Reporting (Raquel Espinosa)
 Q & A – All
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Announcements/Updates
McL FY15 Provisional
Fringe Benefit Rates
• New FY15 McL Fringe Benefit rates have been
submitted to DHHS for approval.
• When the new rate agreement has been issued, a
more complete update will be given.
• Until then the provisional fringe benefit rates below will
be charged to all research grants.
• Current Rate agreement is still dated September 13,
2012.
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IDC - MIC Scanning Costs
• Direct costs of MIC Scans to remain unchanged at $550 per
hour
• Currently seeking guidance to NIH awarding agencies about
how to treat the indirect costs charges on grant applications
on active and pending awards. Differential treatment among
NIH agencies is due to budget availability.
• NIMH: encourages submission of supplement requests using
SF424 supplement package; couching PI’s to talk with their
PO’s about unforeseen costs on projects
• Further guidance pending from NIDA and NIAAA
• Communication will be sent out when more information is
available
PeopleSoft DHHS Salary
Cap Implementation
DRAW
05/19/2015
Project Managers:
Anthony Cassese [email protected]
Cora Cheng-Chong [email protected]
© Partners HealthCare System, Inc.,
2012
Current State:
Statistics:

Approximately 650 employees, or 40% of the total number of personnel
charged to DHHS funds, have a pay rate greater than the current DHHS
Salary Cap

This accounts for 65% of the total salary, in dollars, charged to DHHS funds
Current State of EDC/RPO:

Complying with DHHS Salary cap currently requires manual input

No internal functions that automatically apply the correct DHHS Cap to the
corresponding fund

Salary cap may fluctuate, complicating salary and effort distributions
throughout the years to come
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Future State:
Future State of EDC/RPO:

Automated distribution calculation based on Cap %

Appropriate Cap will apply to each DHHS Fund

Added Visual Assurance
What the System Will Do For You:
1. Apply the DHHS Salary Cap to all projects with 070 fund code
2. Restrict Over-the-Cap Distributions to non-sponsored research funds
• (PO, Department, Sundry, and Operating)
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Applicable DHHS Agencies:
Fund code 070 includes:
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National Institutes of Health (NIH)
Agency for Healthcare Research and Quality (AHRQ)
Center for Disease Control and Prevention (CDC)
Food and Drug Administration (FDA)
Health Resources and Services Administration (HRSA)
Substance Abuse and Mental Health Services Administration (SAMHSA)
Administration for Children and Families (ACF)
Administration for Community Living (ACL)
Agency for Toxic Substances and Disease Registry (ATSDR)
Centers for Medicare and Medicaid Services (CMS)
Indian Health Service (IHS)
New Functionality:
1. Cap % - This is the percentage that the submitter will enter new distributions for
any changes against DHHS funds (code 070); Entering the Cap % calculates the
Distribution % based on the appropriate cap for each DHHS Fund
2. Annual Amount Over Cap - A calculation that provides the amount over the
cap that cannot be charged to sponsored research
3. Budget Start/End – This is a new feature now displaying on all RPOs and EDCs
4. Cap Applied – The appropriate cap to be applied based on hourly rate; If the
hourly rate is in excess of the cap hourly rate, the cap will apply
5. Cap Effective Date – The effective date of the cap being applied
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Determining the Appropriate Cap: DHHS Cap Table
Effective
Date
Executive
Level
Salary Cap
Amount
Hourly Cap
% Increase
(Decrease)
01/11/2015
II
$183,300
$88.125
1%
01/12/2014
II
$181,500
$87.259615
1%
12/23/2011
II
$179,700
$86.394231
(10%)
01/01/2010
I
$199,700
$96.009615
1.25%
How does PS apply the correct cap?
•
•
•
Effective Date of the Transaction
Budget Start Date for each DHHS fund
Increase or Decrease in Cap
DHHS Cap Policy:
•
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If the Cap decreases the Cap is not effective until the non-competing renewal
start date
If the Cap increases the Cap may be effective immediately, or can be effective
at the non-competing renewal start date
– Up to the PI to rebudget funds to accommodate the increase in cap against the
fund, while keeping the same effort
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Cap Overage:
Overage Cannot Be Allocated to
Fund Codes:
 070 DHHS
 071 Other Federal
 072 Non-Federal
 068 Private Foundation
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Overage Must Be Allocated
to Fund Codes:
 066 Research Sundry
 064 Non-Research Sundry
 011 Non-Research
 PO/Operating
 All Other
•
40 FTEs and 32 PTEs require distribution adjustments across MGH
and BWH
•
Outreach will occur to those departments
Outreach and Training:
Date
Communication/Event
Information to be Shared
Method
May 6
MGH – Dept. Medicine
Overview of changes, upcoming
training schedule, etc.
Meeting
May 12
MGH - RADG
Overview of changes, upcoming
training schedule, etc.
Formal
Presentation
May 13
Overview of changes, upcoming
Research Advisory Forum training schedule, etc.; Gather
feedback regarding rollout timeline
From Whom
Anthony C.
Eleni R.
Anthony C.
Cora C.
Eleni R.
Meeting
Anthony C.
Cora C.
Eleni R.
Formal
Presentation
Anthony C.
Cora C.
Eleni R.
May 14
BWH - BRISC
Overview of changes, upcoming
training schedule, etc.
After
RADG/
BRISC
Research Community
Reinforcement of RADG/BRISC
presentations
Research
Navigator
Anthony C.
May 18
VP General
Communication
Email explaining the changes,
purpose and preparedness
Email
VPs
May 19
McLean – DRAW
Overview of changes, upcoming
training schedule, etc.
Formal
Presentation
Anthony C.
Cora C.
Eleni R.
May 19
VP Targeted
Communication
Targeted to departments requiring
distribution adjustments
Email
VPs
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Outreach and Training:
Date /
Timing
Communication/Event
Information to Be Shared
Method
From Whom
May 20May 29
Recruitment of DAs for
Tier-1 Training/Testing
Outreach to affected departments
to recruit DAs for training
Email/Phone
call
Anthony /
Cora / PostAward GAs
June 1 –
June 12
Tier I – Testing With
Target Group
Training at RM with target group
of at-risk departments, will also
serve as Phase 2 UAT
Training
Anthony C.
June 8
Recruitment of DAs for
Tier 2 Training/Testing
Outreach to research community
to recruit DAs for training
Email/Phone/
Navigator
Anthony C.
Cora C.
Post-Award
GAs
June 15 –
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Tier II – Open Training
Open trainings for departments
who want help
Training
Anthony C.
Directly Affected
Individuals / Departments
Personal outreach to those we
know will be directly affected by
the changes
Anthony C.
Email / Phone Cora C.
/ Face-to-Face Post-Award
GAs
Research Community
Final reminder / rollout
announcement; Info on office
hours, trainings, and webinars
Research
Navigator /
Email
20th-
July
July 31th
Rollout
Date:
August 1
Tentative
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Anthony C./
Post-Award
GAs
Questions?
Please feel free to contact us with any questions, concerns, and or ideas
Cora Cheng-Chong (Manager, Post-Award)
(e) [email protected]
(p) (617) 945-9506
Anthony Cassese (Senior Grant Administrator, Post-Award)
(e) [email protected]
(p) (617) 954-9589
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Research Finance
Journal Entries/Cost Transfers
Partners Research Management Education & Training Program
https://partnershealthcare.sharepoint.com/sites/phrmresources/t
© Partners HealthCare System, Inc.,
2015
Journal Entries—The “Five Ws”
A journal entry is a mechanism for transferring non-personnel costs from
one project to another. Journal entries are a shared responsibility
between the PI, DA and Research Finance
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
“Five Ws”: Every transaction must identify the
who, what, when, where and why of the cost being
journal transferred.
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The “Five Ws” identify the characteristics that are
unique to each transaction and document the
basis for submitting the journal entry.
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Financial records appropriately documenting the
transactions must support all journal entries and
are the responsibility of the originating department
to maintain.
Journal Entries—Roles and Responsibilities
Roles
Principal Investigators (PIs)
Responsibilities
Validate each research project’s expense activity on an ongoing basis to ensure
that expenses have been charged to the correct funding source
Identify expense posting errors and initiate corrective action by asking their DAs to
prepare and submit a journal entry to Research Management
Provide appropriate justification and designate the fund that should receive the
transfer
Review fund balances to verify that the cost transfer took place
Department Administrators (DAs)
Use the journal entry template to prepare and submit journal entries to transfer non
personnel/non-salary costs and to book original costs (such as core services) onto
sponsored project funds
Maintain supporting documentation/records for all journal entries
Research Finance Specialists
Check that the journal entry template is complete and correct and includes the "5
Ws" (the reasons behind the transaction)
Confirm that the journal entry is accompanied by appropriate documentation and
signatures (when required)
Verify that transactions are between active cost centers
Validate that the cost center being debited has sufficient funds to cover the
transaction
Confirm that transactions occur within the active period of the project
Check that journal entry transactions follow standard Partners accounting
practices and policies
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Journal Entry Types
Standard Cost Transfers
Entries to Book Original Cost
Cost Transfers > 90 days
 Journal Entry templates can be found on the Research Navigator,
under “Forms, Tools and Resources”
 Regardless of type, all entries must conform to generally accepted
accounting principles and be supported by documentation
maintained by the department of origin.
 All transactions must be moved at an itemized level.
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Journal Entry Template
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Cost Transfer Policy
Cost transfers are appropriate when they are reasonable, allocable,
allowable, and consistently applied (as defined by Partners’ Sponsored
Project Cost Charging Policy, Federal Regulation 45 CFR Part 74, and
OMB Circular A-110 C.25, Subpart D71).
The purpose of a cost transfer is to correct errors in the processing of
the original charges; to move costs between funds for closely related
work that is supported by more than one funding source, or to transfer
pre-award costs to a fund in accordance with the provisions of the
award.
At no time should sponsored project funds be used as a holding
account for expenses that will then be transferred, pending the
continuation, renewal or modification of the project or the receipt of a
new award. Transfers from one project to another or from one
competing segment to the next simply to cover overruns are not
allowable.
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Cost Transfer Policy
Partners defines the 90 day period for retroactive transfers as
follows:
The 90-day timeframe is determined by the month that the original
charge, or expense, is recorded. For example, if the original charge
is recorded in the general ledger any time during May (i.e., May
Document Direct report or Insight download) a complete, authorized
cost transfer form with all required back-up would have to be
received by Research Management by the last business day in
August to be within the 90 day timeframe. The date of a purchase
order requisition or a date of hire, for example, is not material for this
calculation.
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Why Audit Trail Data?
Audit trail data proves that the transaction exists but does not
provide assurance that the cost belongs on a grant.
The information provided by the PI and the Department
Administrator certifies that the cost belongs to a grant.
Cost transfers which contain expenses that are not approved
by Research Management or disallowed as the result of an
audit finding become the financial responsibility of the PI and
department.
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Standard Cost Transfers
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Standard cost transfers move a cost that has already hit the general ledger from
one cost center to another.
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To qualify as a standard cost transfer, the journal entry must be submitted
within 90 days of the original transaction as defined by the Partners
Research Management Cost Transfer Policy.
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Standard Cost Transfer audit trail data consist of the following:
 The PHS voucher number
 Transaction posting date from the general ledger
 A brief explanation of why the cost is being moved
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Department administrators should focus on the inclusion of adequate audit trail
data and comments that sufficiently explain the basis for the entry:
Who is requesting the journal entry?
What change is the journal entry requesting?
When was the cost charged to the general ledger?
Where is the cost being transferred?
Why is the cost being transferred?
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Insufficient Journal Entry Explanations:
 The wrong account was charged
 Costs do not belong on the fund where they were charged
 Move costs to correct account
 Debit account x (cost center listed in debit column) or credit cost center
y (cost center listed in credit column)
 Transfer in or transfer out
 Move cost overrun to cost center z (this would suffice if cost being
moved to a sundry)
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Reasonable Justifications
 Costs temporarily charged to sundry are now moved to fund xxxxxx
due to delayed fund set up. Project start date is 3/1/2008 award
was activated 5/22/2008. All costs identified by PI as supporting the
scientific objectives of project xxxxxx.
 Costs originally allocated to fund xxxxxx are now redistributed based
on shared use of lab supplies. PI determined a 50/50 split between
the two projects based on work completed for the last two months.
 Distribute shared supplies based on actual project usage for the
months of May and June 2008.
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Journal Entries to Book Original Costs
Journal entries that post original expenses must establish an audit trail because
they are the initial posting of the expense to the general ledger.
This includes but is not limited to core service facilities and payment for
interdepartmental services rendered.
Invoices need to include the following information:
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Vendor name/address and authorized signature or letterhead
Name/address of goods/services recipient
Current date
Clear description of the goods/services provided (including date of service
and itemized cost)
 Invoice number
 Supporting documentation for this type of entry is the invoice being paid.
Invoice copies must therefore accompany the entry when submitted to
Research Finance for review.
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>90 Day Cost Transfers
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
Greater than 90 days as defined by PHS Cost Transfer policy
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Description of the expenses being transferred, including why and when
the original charge(s) occurred
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Reason why the receiving account was not originally charged
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Explanation of why it is appropriate to charge the receiving account and
how the expense is allocable to that account
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The reason for the delay in initiating the cost transfer
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Steps taken to avoid late cost transfers in the future
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Research Finance may request additional supporting documentation to
facilitate the review process.
Journal Entry Submission Timelines
Once an approved
journal entry has
been uploaded into
the General Ledger a
confirmation email
containing the
assigned JE# is sent
to the originator.
Journals submitted
by the last business
day of the month are
reviewed by
Research Finance
for the month end
close.
Core journals are
due by Business Day
15 and are subject to
routine detailed
review.
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Journal Entries—Tools
Tools to assist DA’s with journal entries:
•
Standard journal entry template available on the RM website
•
Policies (on RM website):
–
–
•
Cost Charging Policy
Cost Transfer Policy
Standard Operating Procedures (on RM website):
–
Non-personnel journal entries SOP
Remember that journal entries which move costs from one fund to another
represent confirmation that the costs belong on the fund to which they are
being moved. Therefore, subsequent attempts to move costs that have
already been transferred to a new fund will be denied by Research Finance.
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Effort Reporting Enhancements
Research Compliance Officers Forum
May 8, 2015
Effort Reporting Plan
 1. Move to a hybrid approach for effort reporting
• Professional staff certify their effort as individuals on a semi-annual basis. (current
process)
 PI certifies for non-professional staff on each Federal project that the salary and effort
charged to the award is appropriate. Proposed timeframe for the project certification
coincides with the semi-annual individual certifications. Post-Docs/Fellows will be
captured in this project based certification process. (new process requires new
infrastructure and training)
 This option approved by ROM because it was felt as the alternative that was the least
resource intensive but would still improve compliance.
 2. Have ‘automated’ recertification by investigator triggered by salary change
 Required when salary charged to a project changes by more than 3% from what was
previously certified (new process requires new infrastructure and training)
 3. Require mandatory training for all Department Administrators and Investigators
• Training will be web-based but tracked
• Consequences for non-compliance
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Hybrid Approach Overview & Certification Timing
Individual Effort Reporting
• Semi-annual (Oct and Apr)
Project Based Certification
 Semi-annual (Oct and Apr)
• Professional staff certify individual Effort
Certification Forms (ECFs)
 PI certifies non-professional staff effort
per project
• Usability enhancements are in progress
but does not require new system
 Requires a new system; will have
to be scoped by IS
• ≈ 2,500 individual ECFs each period
 ≈ 3,700 Fed Sponsored Projects to
review and certify each period
Goal is to find a time frame that complements and reinforces the
existing Effort Reporting process
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Automated Recertification Process
• Convert recertification process from manual to electronic
• PeopleSoft Earnings Distribution Change (EDC) or Research Post Only (RPO) feeds to
Insight to review the new salary allocation
• New Effort Certification Form is generated if:
• Salary allocation change affects a prior reporting period
• And salary allocation change affects a project that requires effort reporting
• And change in salary allocated to the fund is >3%
• And new salary allocation is >3% change +/- from the effort previously certified
• Estimated impact is ≈ 500 new ECFs generated annually (based on FY14 populations, not
including potential project based recertifications)
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Mandatory Training
•
Population
 PIs
 Post-Docs/Fellows
 Effort Managers
 Other Research Staff
 All Department Grants Administrators
 Anyone responsible for processing salaries for research personnel
•
Preferred Format
 HealthStream
 On-site at Hospitals
 Partners RM Trainings (trimester schedule)
•
Consequences for non-compliance
 Frequency
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Next Steps
(Highlighted areas where RM needs your help)
 Finalize resources to support the activity – request is in
 Meet with local area institutions including Harvard OSP to review their
quarterly project effort certification process and ecrt System
 Begin to sensitize research community of the upcoming changes
and collect additional feedback
 Develop business requirements with Research Applications Group
 Finalize timeline – key questions relate to approval of FTEs, Insight 4.0
Redesign, training and communication strategy
 Validate Hospital department’s personnel management framework
before the expansion of the population
 Form committee tasked with training, communication and rollout strategy
for each hospital. Include input from:
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Research Management
Research Compliance
Institutional Administrative Representatives
Investigators (Ideally)
Research Applications Group
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Current Effort Cycle Status Update
FY2015 Pd 1 (10/01/14 - 03/31/2015)
PROGRESS BY INSTITUTION
Pre-Review Certification Post-Review
EFFORT REPORTING STATUS (as of 05/05/2015)
Pre-Review Certification Post-Review Completed
Total
51
202
30
2253
2536
Pre-Review
BWH
IHP
MCL
MGH
PHS
SRH
Total
Certification
Post-Review
Completed
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1%
0%
1%
3%
7%
0%
2%
6%
50%
6%
9%
0%
33%
8%
1%
0%
3%
1%
7%
0%
1%
Completed
92%
50%
90%
87%
87%
67%
89%
QUESTIONS?
Contact: Raquel Espinosa
[email protected]
617-855-2868
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