Transcript Document
Grants Management, Financial Responsibilities, and Research Related Issues Carol Hillmer Assistant Dean CALS Research Division November 19, 2003 1 Responsibilities Individuals authorized to sign transmittals and other actions on behalf of their Department/Center need to thoroughly review and understand what they are signing Departmental/Center signatories are responsible for the requests, proposals, documents, etc., which they sign and forward through campus 2 Responsibilities continued CALS Research Division will not approve requests that are unclear, inaccurate, or incomplete Research and Sponsored Programs is delegated signature authority (authorized official) by the Board of Regents for proposals, agreements, contracts, etc. related to extramural support activities of the University 3 Responsibilities continued Principal Investigator is responsible and accountable to the grantee for the proper conduct of the project or activity Authorized official is held responsible by the sponsor to assure that the institution will meet the obligations 4 Responsibilities continued Each of us is a representative of the UW, accountable to the State of Wisconsin, and ultimately responsible for assuring efforts of good stewardship Communications – keep departments/ centers, college, and RSP in the loop 5 Applications, Agreements, etc. Applications are submitted by the University of Wisconsin-Madison on behalf of the Principal Investigator Proposals (pre-, full, electronic) all must route through the department, college, and RSP for review and approval prior to submission to an agency/sponsor 6 Awards Awards are accepted by the University of Wisconsin-Madison and assigned to a Principal Investigator Terms and conditions may be negotiated and must be fully accepted prior to an award number being issued Protocol approvals must be approved prior to an award number being issued 7 Personnel Issues Principal Investigator must be payrolled OR cost shared on the grant – effort must be shown and the level must be reasonable Principal Investigator is responsible and accountable to the grantee for the proper conduct of the project or activity and for overall award management 8 Personnel Issues continued Key personnel are individuals who contribute in a substantial way to the scientific development or execution of the project Includes PI and collaborator(s) May include researchers/scientists Does not include students (undergrads, grads, or post-docts) or general support staff 9 Personnel Issues continued Consultant provides professional advice or services on the basis of a written agreement for a fee expertise or skills add value to the project not an employee Administrative and Clerical support salaries are normally not allowable costs on grants – they are a component of our Indirect Cost Rate 10 Personnel Issues continued Fellowship appointments are as Predoctoral or Post-doctoral Fellows Post-doctoral research appointments are as Research Associates Graduate student research appointments are as Research Assistants 11 Personnel Activity Reports PARs represent an after-the-fact certification of an individual’s actual effort Employees that are payrolled from or cost-shared toward a federallysponsored project are required to complete a PAR Total effort cannot exceed 100% 12 PARs continued Problem – Employees that are costshared toward a non-federallysponsored project are NOT captured on the PAR system Problem – PARs are on occasion inaccurately certified which may be interpreted as an act of fraud 13 Cost Sharing Cost sharing is a portion of the project or program costs which are not borne by the awarding agency/sponsor Although agencies/sponsors may define cost sharing, matching, and leveraging differently, at UW-Madison each requires the same level of documentation 14 Cost Sharing continued Required versus encouraged versus voluntary If required, only provide up to the required level If encouraged, only include a reasonable level Otherwise, do NOT include All must be documentable 15 Cost Sharing continued When personnel effort = salary plus fringe benefits plus indirect costs (if indirect costs are allowed) When cash – must be captured in a 133 account designated specifically as a “match” account; must be used during the same award period as the award it is being used to match 16 Cost Sharing continued When an award is made, cost sharing of personnel effort must be set up prior to an account number being established http://www.rsp.wisc.edu/forms/costsharefrm.pdf Informational copies of completed forms are sent to the Principal Investigator, Department/Center Administrator, and Individual(s) being cost shared 17 Cost Sharing continued When an award is made, cash match accounts must also be set up prior to an account number being established Other forms of cost sharing – manner of tracking/reporting and who is responsible for such must be defined prior to an account number being established 18 Criteria for Cost Sharing Must be verifiable from the recipient’s accounting records May not be included as a contribution for any other project or program Must be necessary and reasonable for proper and efficient accomplishment of the project or program objectives 19 Criteria for Cost Sharing continued Must be allowable under applicable cost principles Must be provided for in the approved project budget Unrecovered indirect costs may be included with prior approval of the federal awarding agency Federal support cannot be used toward another federal award 20 Financial Issues Do not payroll individuals on awards on which they are not associated/working Payrolling on a grant account as a “holding place” until a new award or continuation funding is received is not allowable Establish advance accounts or utilize unrestricted funding (i.e., 101s, 133 gifts, etc.) 21 Financial Issues continued Be aware of the terms and conditions that apply to each award FDP (Federal Demonstration Partnership) streamlines the administrative process and minimizes the administrative burden while maintaining effective stewardship of federal funds 22 Financial Issues continued Unallowable expenditures: Administrative & clerical salaries Local telephone service Office supplies Postage Dues & memberships Subscriptions, books, & periodicals General purpose equipment (i.e., computers, copy machines, etc.) General computer services, networking costs, & other DoIT services Staff recruitment & relocation 23 Financial Issues continued Use of procurement cards – purchases must be allowable Premium processing fees on visa applications are unallowable Use of daily rate structures are unallowable Special invoicing/reporting requirements flow down to the college and departments/centers 24 Account Numbers in Advance Complete a “Request for Account Number in Advance of Award” (form 881) http://www.rsp.wisc.edu/forms/88-1.pdf Attach copies of approved protocols Attach documentation from the funding agency/sponsor that award is forthcoming 25 Account Number in Advance continued Problem – departments are responsible for incurred costs when an award is not received Problem – 90 day pre-spending is not allowable by all agencies/sponsors Problem – some awards are effective upon date of last signature 26 Subcontracts Subcontract costs represent a collaboration of work by more than one institution UW may be a subcontractor in another agency/institution’s proposal Another agency/institution may be a subcontractor within a proposal/award to UW Paperwork requires agency/institutional approvals prior to inclusion 27 Subcontracts continued http://www.cals.wisc.edu/research/infopolproc.html Issue on a yearly basis Prior to continuation, consult with PI to confirm acceptable performance to date Final period of continuation should end 90 days prior to the official award end date Subs to UW departments are handled via subaccount request form 28 Cost transfers A cost transfer is a transfer of a previously recorded expenditure from one funding source to another Salary payment transfers Non-salary payment transfers 29 Cost Transfers continued Why? Correction of data entry error Service center charges Reallocation of effort Continuation year of a project Pre-award costs 30 Cost Transfers continued When allowable? In accordance with the terms and conditions of the award document Supported by acceptable documentation justifying the transfer Certified as to the correctness of the charge 31 Cost Transfers continued When unallowable? To meet deficiencies caused by overruns or other financial considerations To avoid restrictions imposed by law or by the terms of the sponsored agreement Due to funds terminating with unexpended balances Clean up efforts at the end of an award For convenience After PAR certification has occurred 32 Cost Transfers continued What is required? Documentation! Justification! Clarity and detail! Documentation must include a full explanation of how the situation occurred and actions being taken to alleviate future occurrences 33 Cost Transfers continued Timeliness Must submit as soon as issue is discovered 90-days is the standard CALS strongly encourages actions within 45 days Prior to PAR certification! 34 Cost Transfers continued Recommendations Review accounts monthly Do not use grants for “parking” expenses Set up accounts in advance when appropriate Keep in mind – transfers are a “big red flag” to auditors 35 Gifts-in-Kind Gifts-in-Kind (non-monetary gifts) require formal acceptance by the Board of Regents http://www.rsp.wisc.edu/html/giftinkind.html Route transmittal form through department/center, college, and RSP for review and approval Attach letter from donor 36 Equipment Loans Risk Management has a property program which manages equipment located at off-campus facilities or loaned to another institution For information refer to their website: http://www.bussvc.wisc.edu/risk_mgt/property_program.html For form to authorize equipment loans: http://www.bussvc.wisc.edu/acct/propcont/propform.html 37 No Cost Extensions Extension on an award needs to be requested and approved prior to the award end date Requests need to route from PI through department/center, college, and RSP to the agency/sponsor http://www.cals.wisc.edu/research/forms.html FDP awards – request must still be routed; campus has authority to approve first extension 38 Reporting, Modifications, etc. Communication – keep departments/ centers, college, and RSP in the loop Budget modifications Scope of work/project modifications Addition/deletion of subcontractors or consultants Exceptions Reports Etc. 39 RSP Update Director RSP – William Vance Assistant Director Pre-award – Diane Barrett Assistant Director Post-award – Bob Andresen Policy & Planning Analyst – Francine Massey Pre-award Team 2 – Stephanie Gray, Christy Wipperfurth, and vacancy Post-award – Non federal accountant Jane Braun; Federal accountants by agency; Team transition pending Material transfer agreements – Mark Doremus 40 PALS RSP’s Pre-Award Login System Proposals are logged in when received at RSP Actions/status information is accessible via https://www.rsp.wisc.edu/services/admin/pals/c_slookup.cfm Query by PI Name, UDDS, Agency, etc. CALS will be a test site Departments will be involved through transmittal entry which will capture data and allow for tracking from department/center issuance to college to RSP to agency/sponsor 41 Helpful Websites CALS Research Division http://www.cals.wisc.edu/research Research & Sponsored Programs http://www.rsp.wisc.edu 42 Questions??? How can we help? What can we clarify? Need us to meet with departments, centers, individuals? 43