Transcript Research Administration for the Departmental Administrator

DEPARTMENTAL
ADMINISTRATION
BOOT CAMP:
Research Administration
for the
Department Administrator
Workshop Faculty
Patricia Hawk
Samantha Westcott
Interim Director
Office of Sponsored Programs
Oregon State University
[email protected]
Grant Manager
Division of Biology
California Institute of Technology
[email protected]
Bruce Morgan
Assistant Vice Chancellor
Office of Research
University of California, Riverside
[email protected]
What do you want to take with
you from this workshop?
Topic Areas
Proposals
Award Acceptance
Award Management
Subawards
Closeouts
Audits
We will also include a discussion about Cost Transfers.
Tasks: The Work We Do
Pre-Award
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Funding Opportunities
Proposal Preparation, Review, & Submission
Award Review and Account Set Up
Post-Award
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Cost Management and Account Monitoring
Cost Transfers
Closeout
Guidelines: The Rules We Obey
Federal
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OMB Circulars
Agency Guidelines
State
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Public Institution or
Private Institution
Institutional
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Policies
Procedures
School
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Departmental
Divisional
Investigator
Funding Opportunities
Sponsors:
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Government
Foundations
Corporate
Donors
Opportunities:
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RFA
RFP
PA
Invitation
Discussion: Finding Funding
There’s a New Kid in Town
There is a new faculty
member just hired to the
campus. She is an Assistant
Professor who has had a successful postdoc
experience and has begun her own research but
only has internal funding.
Questions for Discussion
Who provides support for finding funding on
your campus?
If you do it, what tools do you use?
How do you help a new investigator get
‘plugged in’ to your institution?
Proposal Preparation
The major components of a proposal:
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Budget & Justification
Abstract
Statement of Work
Biosketch
Resources/Facilities
Institutional Signoff
Benefits to Success: Proposals
The more time invested by the PI on the
research plan, the better the proposal.
A successful proposal:
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Jobs
Progress
No resubmission
Benefits to Success: Proposals
How the Departmental Administrator helps:
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Correct budget
Guideline review
Formatting
Up-to-date information
Routing and Sign-offs
Confidence
Competence
Budgeting: Basics
Categories
Personnel
Consultants
Equipment
Supplies
Travel
Consortium
Other Direct Costs
Subcategories
Key Personnel
Research Team
Administration
Animal Costs
Human Subjects
Patient Care
Construction
Budgeting: Details
Identify Cost Categories: Unidentified Costs
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May cause overruns on the award
Institution shares in cost of research effort
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May require sponsor approval for rebudgeting
Holds up post-award invoicing and financial reporting
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Bottom line: Not in the budget? Ask.
Personnel Costs: Proposal vs. Expenditures
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Reports of time and effort are certified
Bottom line: Reporting = Audits = Findings
Budgeting: More Details
Itemize Costs Correctly: Follow the Rules
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Salary vs. Stipend
Stipends not allowable on research grants, only on training/
fellowship grants
Employer/employee relationship = salary
Trainee/fellow entitled to living allowance = stipend
Consider immigration status in allowability
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Materials & Supplies vs. Equipment
A-21 threshold for equipment = $5,000 (or institution’s
threshold if lower), with a useful life of at least 1 year
F&A rate applied to materials and supplies, but NOT to
equipment items
Budgeting: More Details
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Travel: domestic vs. foreign
Domestic: in-state or out-of-state
Foreign: allowable with prior approval, certain restrictions apply
Know basis/rates for reimbursement
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Subawards vs. service agreements
Difference between the “big S” and the “little s”
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Programmatic effort (“big S”) vs. goods and services (“little s”)
Impact on F&A/indirect cost recovery
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F&A assessed on only the first $25K of the “big S”
F&A assessed on full amount of “little S”
Flow-down of prime award terms and conditions required for
“big S”, not for little “s”
Subrecipient monitoring required for “big S”, not for “little s”
Budgeting: More Details
Pieces needed for Subaward
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Subawardee budget, SOW, institutional approvals
Impact if not on file or request to issue Sub not
initiated internally
Late issuance
Late start of work by collaborator
Late invoicing and payment
Late reporting
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Remember, your institution as prime recipient is
ultimately responsible for conduct of the work and
meeting sponsor requirements!
Budgeting: More Details
Are costs allowable, allocable, reasonable?
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Sponsor guidelines
OMB Circular A-21
Institutional Rules
Are costs direct or F&A/indirect?
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Direct: costs identifiable to a specific project
Indirect: costs incurred as part of overall operations
Ex: Direct vs. Administrative (F&A) costs
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Salaries and wages of clerical/administrative staff generally
*unallowable* as direct
Exception: meet the test of “major project” as defined in Exhibit C of A21
Application/treatment of costs should be consistent
Budgeting: Hints
Project the future: Look toward reality
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Ask the question: What will it take to do this
project?
Work budget backward starting with total
costs
Compare reality with proposed budget
Plan so that every dollar is utilized to PI and
institution’s best advantage: ask every
question to get the full cost impact from your
PI
Budgeting: More Hints
Impacts of poor planning:
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Loss of direct cost funding available to the
project
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Loss of F&A/indirect cost recovery
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Disallowances
Budgeting: More Hints
Open communication reduces:
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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
Budget Justification
Personnel: Include everyone on the
budget, their effort, role, and detail about
what s/he will do on the project.
Each category in the budget should
include a strong justification for the value
that cost will bring to the project.
Read the instructions, read them again.
Use successful language from previous
applications, if available.
Administrivia
Proposal Format Instructions: Read the
instructions, gather the forms, read the
instructions again
Biosketches
Resources/Facilities Descriptions
Anything required by the sponsor as part
of the proposal
Share with others every successful form
and ask for successful versions
Routing and Sign-Off
Work from the deadline backwards
Maximize time available for the PI to work
on the research plan
Get a working draft with a final budget
routing as early as possible to give
everyone maximum review time
If urgent, CALL FIRST – give your
colleagues fair warning
Award Management
Pre-Award Setup
Award Review
Set-Up
Assignment of Costs
Monitoring
Cost Transfers
Reporting
Closeout
Pre-Award Accounts
Risks
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Unfunded Proposals
Costs incurred that must be reassigned
Federal to federal: BIG RISK
Federal to discretionary: LOW RISK
Discretionary spent assuming award will arrive
Rewards
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Correct assignment of costs
Fewer cost transfers
Award Review
Type of Award – is this an Assistance
Agreement or a Contract?
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Assistance Agreements are either grants or
cooperative agreements; these are subject to
OMB Circular A-110
Contracts are subject to the Federal
Acquisition Regulations
Award Review
Budget
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Reduced?
Reduce the Scope of Work and Cost Sharing
Accordingly
Performance Period
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Align it with the workflow
Accommodates pre-award costs
Terms & Reporting
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Non-Standard?
Can we live with it?
Award Review
Examples of non-standard terms or
reporting:
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Reporting on labor hours
Detailed expenditure reporting
How do you, as a departmental administrator,
fit into these requirements?
Award Set Up
Accounting Structure
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Plan your large awards ahead of time
Layout your vision of the award structure
Communicate with PI and users of account
prior to set up
Budget
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Align budgets to match requirements of award
Make monitoring easier for everyone
Let’s Take a Break!
Cost Sharing
Cost Sharing: Details
Most institutions’ policies, written or not:
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No cost sharing unless mandated/required by sponsor
Voluntary committed cost sharing
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Faculty/key personnel time and effort stated but not charged to
the sponsored award
Must be tracked and reported upon
Has negative impact on F&A/indirect cost recovery
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Indirect Cost Waivers
Does the difference between your institution’s federally negotiated
rate and the reduced rate you agree to accept on the award
represent cost sharing?
Cost Sharing and the Departmental
Administrator
The most common form of cost sharing is
contributed effort
Contributed effort is captured through your
institution’s effort reporting system
Other types of cost sharing may involve:
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Volunteer effort
Equipment purchases
Case Study
Cost Sharing/Effort Reporting
What is Effort Reporting?
Salaries charged to Federal awards must
be substantiated
Effort reporting requirements are based on
your institution’s cost principles
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A-21
A-87
A-122
45 CFR 74, Appendix E
Procurement
Most institutions have procurement cards that
can be used for small purchases
Small purchases are defined by your institution
All cards require some type of reconciliation
Someone must keep the source documents
(receipts)
Someone should be checking the Excluded
Parties List
More Procurements
Purchases above the small purchase limit
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Sole source vs. competitive bid process
Source documentation typically resides
with the departmental administrator
Purchasing Department is typically
checking the Excluded Parties List
Expenditure Review
Typical reviewable expenditures
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Food
Late charges
Entertainment costs
Foreign travel
Awards and prizes
Monitoring Expenses
Departmental Administrators are actively
involved in monitoring expenses
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Do you run reports?
Do you look at each expense?
Do you look at expenditure reports?
Award Reconciliation
Verify expenses on your sponsored
accounts to ensure they “belong” on that
account (involve your PIs also)
Investigate outstanding expenses
Resolve discrepancies in a timely manner
(most institutions consider within 90 days
as timely)
Case Study
Allocation
Subawards and
Subrecipient Monitoring
Key Concepts
Subaward is an umbrella term that
encompasses:
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Subcontracts (procurement)
Subagreements (assistance flow thru)
Subgrants (assistance flow thru)
Subawards are used to transfer a portion
of the programmatic work and associated
funding to a lower tier entity
Subrecipients v. Vendors
The substance
of the
relationship is
the most
important factor
The relationship
should
determine the
mechanism
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Subaward v. PO
Subrecipient
Vendor
Programmatic
decision-making
responsibilities
Provides goods &
services as part of
normal business
Performance is
measured against
program objectives
Goods & services
are ancillary to
programmatic
activities
Responsible for
federal compliance
requirements
Operates in a
competitive
environment
Mechanism =
Subaward
Mechanism =
P.O.
Accountability
Sponsors may
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audit subrecipients, and
will hold the recipient accountable for the
subrecipient’s performance and subaward
management
A subrecipient’s disallowance becomes
the recipient’s disallowance
Subrecipient Monitoring Responsibilities
Responsibility is shared across many
offices, units and individuals
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Sponsored Programs Administration
Contract and Grant Accounting
Department and Principal Investigator
Know who handles what at your institution
Subrecipient Monitoring Responsibilities
Principal Investigator and department
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Cooperation and coordination is essential
Communication is the key to success
Know how to capture and understand the big
picture by asking questions and knowing where
to get information
Monitoring should be continuous from
proposal through subaward close-out
Subrecipient Monitoring Activities
Review A-133 audit report or recently
audited financial statement
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If findings, have they been resolved and how?
Risk assessment
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Negotiated F&A cost rate?
Recipient of other federal funds?
Designated cognizant audit agency?
Compliance with federal requirements?
Domestic v. foreign?
Subrecipient Monitoring Activities
Certifications, assurances, debarment &
suspension
Technical and financial monitoring
Regulatory approvals
Compliance with subaward terms and
conditions
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Reporting requirements, deliverables, etc.
Questions to Ask
Progress commensurate with claimed costs?
Project delays or results leading in an
unexpected direction?
Timely submission of progress reports?
Amount invoiced exceed amount obligated?
Invoice dates within subaward period?
Are costs allowable and reasonable?
Fulfillment of cost sharing commitments?
Contact SPO When…
A subrecipient submits a prior approval request
or when a subrecipient has taken an action
without prior approval (when it is required)
Non-performance by subrecipient
Failure to comply with subaward terms
Any concerns regarding the allowability of
invoiced expenses
Subaward Close-out
Project performance – confirm completion of the
scope of work
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Project deliverables, timely final report submission
Financial reviews – review claimed costs for
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Disallowances/allowable costs
Use of proper rates
Fulfillment of cost sharing commitment
Coordinate authorization of final payment with
SPO, Contract & Grant Accounting and PI
Subawards – 3 Dos and 1 Don’t
Do be proactive and facilitative
Do know who to communicate with and when
Do monitor subrecipients throughout the life of a
subaward
Don’t make assumptions
Closeouts
Departmental administrators are actively
involved in closeout
Items to consider in closeout:
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Adjustments need to be done in a timely
manner
Source documentation typically resides at the
department level
Fixed price agreements may have a residual
balance—what happens to that?
Closeout
Good project management of the life of a
project will help to minimize problems at
the closeout stage
Record Retention
Think source documentation
Be aware of record retention requirements
at your institution
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Federal requirements are typically three years
after submission of final financial report
Remember that access to records by
agency, Inspector General or Comptroller
General is allowable
Audits
To Avoid an Audit or Audit Findings
Prepare a thorough, fact-based proposal.
Review and tune-up financial,
administrative, and project management
systems.
READ and UNDERSTAND before you
sign and revisit award requirements
frequently during the project
To Avoid an Audit or Audit Findings
Ensure all staff understand the project and
award requirements and that they
communicate fully and frequently
throughout the project.
If in doubt, ASK QUESTIONS and get
answers and approvals BEFORE acting.
Know your contacts.
To Avoid an Audit or Audit Findings
DOCUMENT, DOCUMENT, DOCUMENT!
Attend training.
Respond fully and timely at every
opportunity during the audit and resolution.
How an Inspector General Audits
They audit in accordance with:
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Government Auditing Standards
AICPA Standards
The Inspector General Act, as amended
They built upon your A-133 and other
audits where relevant to an audit objective.
How An Inspector General Audits
An Inspector General Audits in accordance
with criteria:
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Award
Terms and Conditions
Proposal and Amending Letters
Assurances
Uniform Administrative Requirements
Federal Cost Principles
Laws, Regulations, and Program Guidance
Prudent Business Person
Cost Transfers
Sharing our Stories
Review
Proposals
Awards
Subawards
Closeout
Audits
What do you want to take with
you from this workshop?