Transcript Audit Update - California Institute of Technology

Research Administration Forum
February 3, 2009
What is new in Research
Administration?
Dick Seligman
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new Research Administration Website
Yale University Settlement
Audit update
new Export Compliance policy
Restricted Party Screening
Agency updates
Future Training Sessions
Answering questions
http://researchadministration.caltech.edu
Yale University
$7.6 Million Settlement
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Multi-year investigation by Federal agencies
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DHHS OIG
NSF OIG
DOE OIG
DOD DCAA
NASA OIG
FBI
Yale University
$7.6 Million Settlement
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Period covered:
January 2000 – December 2006
$3 Billion in Federal grants
Basis of the settlement:
 $3.8 Million “actual damages”
 $3.8 Million “penalties”
Yale University
$7.6 Million Settlement
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Issues
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Improper Cost Transfers
Salary charges to grants must reflect
actual time and effort spent
So what?
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Wake-up call for the rest of us
Heightened scrutiny
Project Accounting
Audit Update
Estella Venegas
Audit Update
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FY2008 A-133 Audit conducted by
PricewaterhouseCoopers (PwC)
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DCAA FY2007 Incurred Cost Proposal (ICP)
Audit
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Cost sharing
Financial reporting
Payroll distribution confirmation reports
Financial reports submitted by Project Accounting
Award summaries and sponsor invoicing
DCAA FY2008 Interdivisional Cost Transfer
Audit
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Caltech expenditures and invoicing of JPL awards
Audit Update
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DCAA FY2008 MAAR 5 (Mandatory Annual
Audit Requirement)
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Refunds and credits due to JPL/NASA
Lawrence Livermore National Laboratories
(LLNL) Agency Award Audit
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Caltech expenditures and invoicing of LLNL
contract
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Other Audit Requests
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Reference:
http://www.whitehouse.gov/omb/circulars/a133/a133.html
What is new in Export Compliance?
Adilia Koch
Institute Policy Announcement
To:
The Caltech Community
From:
Subject:
Jean-Lou Chameau
Compliance with Export Laws and Regulations
Federal laws and regulations concerning export, import and financial transactions involving sanctioned or
embargoed countries have existed for many years. The events of September 11, 2001, and subsequent
events around the world have pushed national security concerns to the forefront. The government has
responded by tightening the export control regulations that govern the transfer of strategic technology
for national security and foreign policy reasons.
Export control laws are intended to control the transfer of sensitive information or goods to individuals,
entities, or countries of concern and, under certain conditions, to foreign persons. The regulations
contain a fundamental research exclusion and specific university exemptions that allow most of the
research activities being performed at Caltech and at other U.S. universities to be carried out without the
need for government licenses or other restrictions. There are certain activities and information that are
not covered by the fundamental research exclusion, however, and remain subject to the export control
laws and regulations.
It is essential for all members of the Caltech Community to be aware of them. Toward that end, we
have adopted a new policy, "Compliance with Export Laws and Regulations." While the policy applies to
all members of the Caltech community, there are many who will not be directly affected by the
requirements of this policy.
The Caltech Export Compliance Office will continue to offer export compliance awareness classes for
faculty and staff on these requirements. The schedule of training programs for 2009 will be announced
in January. However, if you need immediate assistance or have any questions regarding this policy,
please contact Caltech's Director of Export Compliance, Adilia F. Koch, at extension 4469 or email:
[email protected].
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The policy can be accessed at: http://cit.hr.caltech.edu/policies/Policies/CITPolicy_ExportLaw.pdf
http://cit.hr.caltech.edu/policies/Policies
/CITPolicy_ExportLaw.pdf
What is this new Institute Policy?
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A clear statement of commitment
by Caltech’s senior officers
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Communicated to the Caltech
community
To comply with US export laws and
regulations
Why do we need this policy?
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Recommended Best Practices
It will mitigate risk should
something go wrong
It serves as the foundation of the
larger Export Compliance
Management Program
What are the effects of this policy?
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Export Compliance Education Program for campus
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International Shipments reviewed to ensure:
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Faculty & Researchers
Administrative Staff
Compliance with export/import regulations and to
determine whether an export license is required.
Creation of new processes and procedures for
some organizations
What else is new?
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MK Denial Restricted Party Screening Tool
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A campus wide web-based tool vs. limited #
Will ensure we are not involved with unauthorized
entities or individuals
Current Users:
 OSR
 Mail Services
 Shipping & Receiving
 Procurement
 Export Compliance, Other
Tool is very simple to use
MK Denial RPS Search
MK Denial RPS Search Results
When should we perform RPS?
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When engaging in a financial or export
transaction involving unknown individuals
or entities
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When a transaction raises a “red flag”
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MK Denial
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Acquire a user name and password from
the Export Compliance Office if you
have a concern about a transaction.
Contact Us
Export Compliance Office
(626) 395-2641
(626) 395-3144 (fax)
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Web:
http://researchadministration.caltech.edu/ec
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Email: [email protected]
Sponsored Research Agency Updates
David Mayo
Agency Updates
NSF
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Postdoc Mentoring Activities description:
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Required:
 As a separate section
 In any proposal that includes funding for
postdocs
 Within 15 page limit of Project Description
Proposals will be returned by NSF if there is
no section addressing this topic
(Grant Proposal Guide Chapter II, Section C.2d(i))
Agency Updates
NIH
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2009 NIH Salary Cap
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$196,700 (up from $191,300 for 2008)
Effective January 1, 2009
http://grants.nih.gov/grants/guide/notice-files/NOTOD-09-037.html
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Career Development (K) applications
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Electronic submission goes electronic on
February 12 (e.g., via Grants.gov)
Reference letters will be submitted directly to
NIH Commons after submission of proposal
Agency Updates
DoD
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Cap on F&A has been carried into 2009
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Limits F&A recovery to 35% of TC
Applies to:
 New/Renewal awards issued in FY2008 &
FY2009
 Year 2 funding of awards issued in FY2008
Standard burden schedule will apply
Will not impact direct costs available to PI
Agency Updates
F&A in Proposals
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Caltech F&A Rate Agreement
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Negotiated with the federal government
Used on all federal and non-federal proposals
On-campus rate (60.5%) applies by default
Off-campus rate (26.0%) - proposal must
clearly demonstrate that the off-campus rate is
applicable
Use of on- and off-campus rates in the same
proposal requires prior discussion with OSR
Agency Updates
F&A in Proposals (cont.)
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Exceptions to Caltech’s F&A Rate
Agreement:
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Reduced or zero F&A based on sponsor policy does
not require special approval, however…
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Must be a federal or non-profit sponsor
Must be a published policy
Must be a requirement for submission
Sponsor’s reduced F&A must be assessed on
all budget categories, unless a category is
specifically exempted by the sponsor’s policy
All other exceptions require prior approval of the
Vice Provost for Research; Research Administration
does not have the authority to approve waivers
Agency Updates
F&A in Proposals (cont.)
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Remember, F&A recovery lower than Caltech’s
negotiated on- or off-campus rates
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Pools
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requires use of the higher tuition
remission rate (85%) in non-federal
proposals
Future Training Sessions
Fundamentals of Research Administration
February 27, 2009
9:00-11:30am
202 Guggenheim
Annual Export Compliance Update
March 24, 2009
10:00-11:30am
151 Sloan
please RSVP to [email protected]
Questions & Suggestions
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Any future Forum topic suggestions
can be dropped off in the
suggestion box at the sign-in table.
Questions can also be placed in the
box.