Transcript Post Award MUHAS, Dartmouth, UCSF Financial Reporting & Closeouts Tuesday October 21, 2014

Post Award
MUHAS, Dartmouth, UCSF
Financial Reporting & Closeouts
Tuesday October 21, 2014
Agenda
O Foundations of good financial reporting
O Types of financial reports
O Financial reporting requirements for
selected sponsors
Lifecycle of an Award
Application
Closeout
Notice of Award
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Internal Controls
Regulation
Contractual
Obligations
Reporting and
Documentation
Reporting and
Publication
Account Setup
Project
Implementation
Foundations of Good Financial
Reporting
O Starts with account set up which facilitates
financial reporting by:
O Segregating expenses into separate accounts
O Mirror reporting cycle in terms duration of
award period and timing of reports
O Mirrors the level of detail of reports by either
expense type or program activity
O Accurate, timely, relevant, useful
Elements of a Good Financial System
Expense
classifications
Provides a clear set of expense types that provide
meaningful information and identification of allowable
and unallowable costs
Transaction
level detail
Able to record and produce reports with sufficient
transaction detail (date paid, vendor, employee,
amount, reference number, etc)
Direct versus
Indirect costs
Able clearly distinguish direct costs versus application
of a rate for indirect costs
Records fiscal
year
Able to “close” transaction data on both a monthly and
fiscal year basis
Discussion: What are other “essential” elements? What are
“nice to haves?”
More Considerations for a
Financial Reporting System
O Official records (not a shadow system) that is
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incorporated into the institution’s financial
statements
Users should have clarity on who enters data
into the system and when (who to call if
something doesn’t look correct)
Tools should be easy to use, on-line
Standard reports should be made available to
facilitate sponsor reporting
Allow downloads of data to facilitate
reconciliation and projections.
Financial Reporting: Roles
and Responsibilities
O Who is responsible for preparing and
submitting financial reports?
O Centralized? Decentralized?
O What are the checks and balances to assure
that reported amounts tie to your “system of
record”?
O Is there need/value in having separation of
duties between the administrator that
initiates transactions and the person
submitting the report?
Types of Financial Reports
Sponsor reporting
• Most sponsors require (even gifts sometimes)
• Award requirement
• Assures stewardship and accountability to tax
payers and donors
• Usually ties to cash
• Identifies amounts to carryover
Principal
Investigator
reporting
• Management tool
• Compliance tool for allocability and relation to
objectives
Division reporting
• Plan resources
• Strategic planning
• Productivity
Institutional
reporting
• Financial statements
• Audits
• Strategic planning
Discussion: Do you have any
awards with cost sharing or
matching requirements?
O How do you track the cost sharing?
O How do you demonstrate that you have met
your obligation to an auditor?
NIH Financial Reports
Federal Financial Report (FFR)(SF-425)
Expenditure Data
O
Uniform Guidance
makes stricter
rules
Timely - Must adhere to submission deadlines:
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Annual –
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FFR submitted for each budget period no later than 90 days after the
end of the calendar quarter (CQ) in which the budget period ended.
 Budget period ends 1/31/2011 – FFR due 6/30/11
(90 days after the end of the CQ of 3/31/11)
O
Final (End of Competitive Segment) –FFR submitted within 90
days following the end of the project period
NIH Reporting Requirements
O Progress reports are required at least
annually
O The Non-Competing Continuation Progress
Report (PHS 2590)
O Progress reports must be submitted
electronically using the Research
Performance Progress Report (RPPR)
Sample Report Timeline
Before End Date of Grant
90 days
•OSP reminds PI
and staff of end
date
•Discuss need for
no-cost extension
•Reminds PI of
technical reports
60 days
•Reviews expenses
incurred not paid
•Reviews
appropriate
charges that can
made to the grant
•Contacts
Subcontractors to
remind of final bill
due within 45 days
of end date
After End date
30 days
•Establish new
account number if
another year
•Prepare
paperwork to move
salary to new
accounts
•Notify PI and staff
of new account
Grant
Close
Financial Report
Preparation
•Prepare final
reconciliation
•Identify pending
expenses
•Collect final
subcontractor
invoices
•Prepare report for
submission within
90 days
Terminology
O Closeout: process by which all applicable
administrative actions and all required work
of the award have been completed
O Total expenses = Cash received
O Reports filed, usually include:
O Final Financial Report
O Final Progress Report
O Final Invention Statement
Unobligated Balances and
Carryover
O Disposition of unobligated balances is
determined by the award notice and sponsor
terms
O If the award is unclear, ask for clarification
O Some sponsors will allow a request to carryover
unspent funds to be used in the next year; some
will not
O Always put requests in writing and submit to the
appropriate sponsor official (for NIH, it’s the
grants specialist, not the Program Officer)
Uniform Guidance and
Financial Reporting
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The non-Federal entity must submit, no later than 90 calendar days
after the end date of the period of performance, all financial,
performance, and other reports as required by or the terms and
conditions of the Federal award. The Federal awarding agency or passthrough entity may approve extensions when requested by the nonFederal entity.
Unless the Federal awarding agency or pass-through entity authorizes
an extension, a non-Federal entity must liquidate all obligations
incurred under the Federal award not later than 90 calendar days after
the end date of the period of performance as specified in the terms
and conditions of the Federal award.
The Federal awarding agency or pass-through entity should complete all
closeout actions for Federal awards no later than one year after receipt
and acceptance of all required final reports.
Expect that US federal sponsors will act more quickly in closing grants
and may do so unilateraly
As a subrecipient, expect shorter time frames for reporting and
invoicing
References
NIH Financial Reports
O
NIH Updating Grant Closeout Policies and Procedures to Align with
New HHS Requirements Notice Number: NOT-OD-14-084
O
Anticipated changes will focus on condensing the timeframe for
reconciling discrepancies between financial expenditures and cash
transactions reports and for resolving other post-submission issues
affecting acceptance of the final Federal Financial Report (FFR) –
NIH Grant Closeout Forms:
http://grants.nih.gov/grants/forms.htm
O Frequently Asked Questions Grants Closeout
http://grants.nih.gov/grants/closeout/faq_grants_closeout.htm
O