Transcript Document

Grants Management,
Financial Responsibilities,
and Research Related Issues
Carol Hillmer
Assistant Dean
CALS Research Division
November 19, 2003
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Responsibilities
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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
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Responsibilities continued
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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
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Responsibilities continued
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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
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Responsibilities continued
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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
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Applications, Agreements, etc.
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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
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Awards
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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
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Personnel Issues
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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
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Personnel Issues continued
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Key personnel are individuals who
contribute in a substantial way to the
scientific development or execution of
the project
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Includes PI and collaborator(s)
May include researchers/scientists
Does not include students (undergrads,
grads, or post-docts) or general support
staff
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Personnel Issues continued
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Consultant
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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
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Personnel Issues continued
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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
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Personnel Activity Reports
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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%
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PARs continued
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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
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Cost Sharing
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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
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Cost Sharing continued
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Required versus encouraged versus
voluntary
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If required, only provide up to the required
level
If encouraged, only include a reasonable
level
Otherwise, do NOT include
All must be documentable
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Cost Sharing continued
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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
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Cost Sharing continued
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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
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Cost Sharing continued
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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
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Criteria for Cost Sharing
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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
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Criteria for Cost Sharing continued
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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
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Financial Issues
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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.)
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Financial Issues continued
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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
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Financial Issues continued
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Unallowable expenditures:
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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
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Financial Issues continued
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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
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Account Numbers in Advance
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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
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Account Number in Advance continued
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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
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Subcontracts
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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
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Subcontracts continued
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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
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Cost transfers
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A cost transfer is a transfer of a
previously recorded expenditure from
one funding source to another
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Salary payment transfers
Non-salary payment transfers
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Cost Transfers continued
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Why?
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Correction of data entry error
Service center charges
Reallocation of effort
Continuation year of a project
Pre-award costs
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Cost Transfers continued
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When allowable?
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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
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Cost Transfers continued
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When unallowable?
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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
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Cost Transfers continued
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What is required?
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Documentation!
Justification!
Clarity and detail!
Documentation must include a full
explanation of how the situation
occurred and actions being taken to
alleviate future occurrences
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Cost Transfers continued
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Timeliness
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Must submit as soon as issue is discovered
90-days is the standard
CALS strongly encourages actions within 45
days
Prior to PAR certification!
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Cost Transfers continued
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Recommendations
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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
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Gifts-in-Kind
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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
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Equipment Loans
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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:
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http://www.bussvc.wisc.edu/risk_mgt/property_program.html
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For form to authorize equipment loans:
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http://www.bussvc.wisc.edu/acct/propcont/propform.html
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No Cost Extensions
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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
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Reporting, Modifications, etc.
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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.
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RSP Update
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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
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PALS
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RSP’s Pre-Award Login System
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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
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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
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Helpful Websites
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CALS Research Division
http://www.cals.wisc.edu/research
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Research & Sponsored Programs
http://www.rsp.wisc.edu
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Questions???
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How can we help?
What can we clarify?
Need us to meet with departments,
centers, individuals?
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