Transcript Post-Award Issues for the Pre

Post-Award Issues for the
Pre-Award Administrator
Panelists:
Tim Leung
Senior Research Accountant
Stanford University
Craig Johnson
Compliance Analyst
University of Washington
Csilla M. Csaplár
Contract & Grant Officer
Stanford University
Agenda
• Discussion of common issues (and solutions)
that arise during proposal development and
award stage that impact post-award
• Terms and conditions to avoid
• Ways to be proactive!
• Building the bridge between pre-award and postaward to facilitate effective
project management
Budgets
• Identify Cost Categories
– Unidentified costs
– May require sponsor approval for rebudgeting
– Bottom line: Not in the budget? Ask.
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Personnel Costs: Proposal vs. Expenditures
Materials/Supplies vs. Equipment
Subawards vs. subcontracts
Correct rates applied
Budgets, continued
• Budget projections
• Impacts of poor planning:
– Loss of direct cost funding available to the project
– Loss of F&A/indirect cost recovery
– Disallowances
• Open communication reduces potential for:
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Excessive, inappropriate, or late cost transfers
Manual adjustments
Disallowances
Revised invoices/financial reports
Audit findings
Loss of expanded authorities or letter of credit drawdown
eligibility
Awards
• Award classification – award type, award instrument,
sponsor type
• Single PI vs. Multiple PIs
– One shared account or separate accounts for each?
– PIs from different departments/divisions
– Access? Controls?
• Budget years vs. cumulative project period
– Separate accounts?
– Is carryforward automatic or is prior approval required?
Award Notices
• Identify important information that post-award
will need
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Payment terms or schedule
Financial reporting requirements and timelines
PO or award number to be included on invoice
Restrictions
Milestones
Award Set-up
• Interest earned
– Return to sponsor?
– Use toward the project?
– For use at institution’s discretion?
• Tracking
• Reporting
• Interest Income
– Tracked separately from revenue
– Recorded as income, not expense
• Cost sharing
Award Set-up, continued
• Period of Performance dates
– Effective date vs. execution date
– Funding authorizations
• Budget periods
• Incremental funding
• Supplemental funding
– Impacts allowability of expenditures
• Rebudgeting
– Institutional policy
– Sponsor policy/prior approval requirements
– Impacts ability to get reimbursed and project planning
Billing/Invoicing
• Invoicing
– Format and documentation
• Standard or Sponsor-specific?
• Back up documentation required (negotiate!)
– Tied to award type - Cost reimbursement or fixed
price
– Frequency
• CR: in arrears monthly, quarterly, semi-annually, annually?
• FP: up-front, per milestones reached, at completion?
• Combination: tied to progress or deliverables?
Payment Terms
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Upon execution/initiation
Fixed schedule of installments
Milestone payments
Upon completion/termination
Withholding of percentage or amount
Net 30 standard
Non-standard can impact institution’s cash flow
Advances/refunds
Reporting Requirements
• Technical
• Progress/interim
• Final
• Financial
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SF 269 and SF 270 for federal awards
Sponsor-specific forms for others
Timeframe for submission – at least 60 days preferable
Who is responsible – department? Central post-award?
• Be timely!
Timely report submission impacts A/R, relationship between central offices
with responsibility/oversight, and PI/institution’s reputation with sponsor
• Delinquent reports may cause sponsors to withhold funding on all awards
• Your institution may be identified as “not responsible”; can impact future
competitions
Sponsor Approvals
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Rebudgeting
Carryforward
Change of PI or level of effort
Pre-award spending
Flowdowns – additional oversight
Compliance Requirements
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Waivers (PI effort, indirect costs)
Human/animals subjects approvals
Cost-sharing
Conflict of Interest
Impacts level of risk to PI, department, and
institution
Sticky Award Terms
• Publication
– Restrictions
– Impacts: restriction on ability to disseminate research results
• Export controls
– Acceptance of controlled or proprietary technology, items covered by
EAR/ITAR
– Impact: loss of fundamental research exclusion
• Intellectual property
– Disclosure internally and to sponsor
– Ownership
– Impacts: loss of ability to file provisional patents, legal battles over
inventorship if proper disclosures not made
• Legal terms (indemnification, venue, governing law, etc.)
Closeout
• Meet with PIs before the grant period is over
• Develop a process
• Use checklists to track items of special concern
(i.e. cost-sharing, unliquidated encumbrances,
final invention statements, etc.)
• Contact your grant accounting team in advance
• Avoid “first among equals” thinking
Terms to Avoid
• Detailed financial reporting and back-up
documentation
• Payments or reporting in non-U.S. dollars
• Reporting deadlines on end date of award (60 days
after end date preferred)
• Final invoicing deadline less than 45 days after end date
• Monthly interim financial reporting
• Return of all award funds if project is terminated early
• Any restrictions on publication
• Others?
Be Proactive!
• Training
– PIs: Explain the process and your expectations, answer questions
– Department administrators: Understand their role and the relationship
with the PI, help facilitate the process with both
– Encourage them to take advantage of training opportunities
• Acting on behalf of the Institution
– Explain the impacts of a poorly planned budget or a rushed proposal
– Remind your team and your departments that you have their interests and
those of the institution in mind
• Get to know your neighborhood
– Meet your customers!
– Know who does what and who can help during a crisis
• Be patient – and be a resource!
Collaborative Solutions
What Pre-award can do:
• Serve as the primary point of contact for the PI, department,
and sponsor
• Learn about and anticipate the needs of your post-award
counterparts
• Understand impacts of award terms and conditions so you can
negotiate the best deal for all the players
• Educate your post-award counterpart on project specifics
• Communicate often, and keep people apprised of your
expectations
• Recognize sponsor restrictions and special requirements,
negotiate to standardize when it makes sense and is possible
• Realize restrictions of institution’s systems, work to
accommodate whenever possible
Collaborative Solutions
What Post-award can do:
• Understand award terms and conditions, and how to
adhere to them
• Interact regularly, not just when there are fires to be put
out
• Ask questions – communication is key
• Be flexible! Not all sponsors and
awards are created equal.
Questions?
Tim Leung
Senior Research Accountant, Stanford University
[email protected]
Craig Johnson
Compliance Analyst, University of Washington
[email protected]
Csilla M. Csaplár
Contract & Grant Officer, Stanford University
[email protected]
With thanks to Marti Dunne, New York University, and Diane Barrett, University of Wisconsin.