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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 2 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. 4 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 7 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) 8 Applicable DHHS Agencies: Fund code 070 includes: 9 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 10 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: • • 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 11 Cap Overage: Overage Cannot Be Allocated to Fund Codes: 070 DHHS 071 Other Federal 072 Non-Federal 068 Private Foundation 12 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 13 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 – 26 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 14 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 15 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 17 “Five Ws”: Every transaction must identify the who, what, when, where and why of the cost being journal transferred. The “Five Ws” identify the characteristics that are unique to each transaction and document the basis for submitting the journal entry. 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 18 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. 19 Journal Entry Template 20 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. 21 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. 22 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. 23 Standard Cost Transfers Standard cost transfers move a cost that has already hit the general ledger from one cost center to another. 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. 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 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? 24 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) 25 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. 26 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: 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. 27 >90 Day Cost Transfers 28 Greater than 90 days as defined by PHS Cost Transfer policy Description of the expenses being transferred, including why and when the original charge(s) occurred Reason why the receiving account was not originally charged Explanation of why it is appropriate to charge the receiving account and how the expense is allocable to that account The reason for the delay in initiating the cost transfer Steps taken to avoid late cost transfers in the future 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. 29 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. 30 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 32 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 33 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) 34 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 35 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: Research Management Research Compliance Institutional Administrative Representatives Investigators (Ideally) Research Applications Group 36 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 37 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 38