Post-Award Process - Office of Research
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Transcript Post-Award Process - Office of Research
GRANTS: CRADLE TO GRAVE
ALUMNI CENTER
BALLROOM
MAY 6, 2014
Post Award Processes
&
Effort Reporting
Roberta McManus
Associate Director – Sponsored Research Administration
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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
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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/
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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
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