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Overview

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Fine line between pre and post award. Handled within one office or two ... Property Reports: Who owns equipment, what is disposition, when was equipment purchased? ... – PowerPoint PPT presentation

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Title: Overview


1
Overview
  • Post-award Issues for the
  • Pre-award and Departmental Administrators
  • What does this mean for you,
  • for your institution?

2
Overview
  • Fine line between pre and post award
  • Handled within one office or two
  • Thorough knowledge is needed from proposal
    preparation to closeout

3
Overview
  • To more effectively and efficiently manage
    research
  • Discussion on a proactive approach to working
    together

4
Outcomes
  • Impact that pre and post award has on the other
  • Impact of the proposal and negotiation process on
    the PI
  • Departmental administrators will understand the
    needs of pre award administrator (and visa versa)

5
The Research Cycle
  • Proposal
  • Award
  • Performance
  • Closeout
  • Audit

6
Award Instruments
  • Grant
  • Contract
  • Cooperative Agreement

7
Definition Grant
  • Purpose is to transfer money, property, services
    or anything of value to recipient in order to
    accomplish a public purpose
  • No substantial involvement anticipated between
    government and recipient

8
Definition Contract
  • Purpose is to acquire property or services for
    direct benefit or use of the federal government
  • Very restrictive. No expectation of cost sharing

9
Definition Cooperative Agreement
  • Purpose is to transfer money, property, services
    or anything of value to recipient in order to
    accomplish a public purpose
  • Substantial involvement anticipated between
    government and recipient

10
Principal Investigator
  • Prep of programmatic proposal
  • Development of project budget
  • Monitor programmatic and financial performance
  • Adhere to terms and conditions of award

11
Principal Investigator
  • Closeout Final progress report, invention
    statement.
  • Financial responsibility and audit

12
Departmental Administrator
  • Assists and advises the PI in preparation of
    proposal, in accordance with sponsor terms and
    conditions, applicable regulations, institutional
    policies

13
Departmental Administrator
  • Assists PI in compliance with award terms and
    conditions, regulations, institutional policies

14
Departmental Administrator
  • Monitors expenditures of award funds, obtains
    necessary authorized signatures

15
Departmental Administrator
  • Coordinates with central offices on reporting

16
Departmental Administrator
  • Assists central administration with closeout and
    audit activities

17
Sponsored Programs Office
  • Review of Proposals for Regulatory and Policy
    Issues
  • Ensure Proper Sign-offs
  • Negotiate Agreements
  • Approve Certain Transactions

18
Review of Proposals
  • Review of RFP, BAA, Program Announcement for
    terms that may be problematic
  • What is PI promising that department and
    post-award staff have to comply with?

19
Ensure Proper Sign-offs
  • Who is Authorized to Approve Proposals/Commit
    resources?
  • Who Can be PI?
  • Acceptance of Risk (Overruns, Cost Sharing,
    Under-recovery of FA)

20
Negotiate Agreements
  • Does contract have requirements that are
    non-standard
  • Who will non-standard terms impact?
  • Will they accept the terms?

21
Negotiate Agreements
  • Examples of non-standard requirements
  • Monthly progress reports
  • Quarterly invoices
  • Sponsor retains title to equipment after period
    of performance

22
Approve Transactions
  • OSP should notify post-award administrators of
    award terms in advance of spending.
  • For example, equipment purchases, travel
    approval, other special requirements of sponsor.

23
Grant/Contract Acctg
  • Review accounting transactions based on
    allowability criteria, terms and conditions, and
    agency guidelines.
  • Review such transactions for compliance with
    University guidelines.

24
Grant/Contract Acctg
  • Review for proper signatures
  • Review for fund availability
  • Prepare billings and financial reports
  • Collect cash

25
Grant/Contract Acctg
  • Maintain effort reporting system
  • Advise PI and departmental administrators on
    financial matters
  • Coordinate A-133 and other audits

26
Shared Responsibilities
  • Stewardship and accountability
  • Effective management of public funds

27
Communication Challenges
  • Sponsor/Institutional Policies
  • Face-to-Face Meetings
  • Websites with up to date information
  • Electronic tools

28
Getting Stakeholders on the Same Page
  • Transmit a copy of award document
  • Inform key staff of award terms and conditions
  • Ensure key staff know and understand
    responsibilities
  • Dialogue during performance period

29
Time is of the Essence
  • Identify problems early and resolve problems as
    soon as possible and with as few parties involved
    as necessary to reach a solution.
  • Attempt to resolve problems promptly
  • Make sure all involved parties understand the
    issue
  • Know when to involve the sponsors

30
Pre-Award/Post-Award Offices A Team Effort
  • Understanding each others roles
    responsibilities
  • Conduct joint staff meetings
  • Conduct joint discussions with departmental
    staff
  • Project a team approach to resolve issues

31
Improving Communication
  • Early review of program announcements,
    solicitations, RFP, etc

32
Improving Communication
  • Identification of unusual sponsor requirements,
    e.g. reporting

33
Improving Communication
  • Discussion of problematic terms prior to proposal
    submission

34
Improving Communication
  • Communications with sponsor, avoiding informal
    agreements

35
Issues in Proposals
  • Cost Accounting Standards
  • Office Supplies
  • Computers
  • General Purpose Equipment
  • Local Telephone

36
Issues in Proposals
  • 5. Dues and Subscriptions
  • 6. Unallowable Cost
  • 7. Know your institutions policies

37
Direct Charging of Administrative Costs
  • OMB Guidance on A-21 Revision to section F. 6.
    (b) (July 1993)
  • In developing the departmental administration
    cost pool, special care should be exercised to
    ensure that costs incurred for the same purpose
    in like circumstances are treated consistently as
    either direct or FA costs ...

38
Direct Charging of Administrative Costs
  • OMB
  • Direct charging ... may be appropriate where a
    major project or activity explicitly budgets for
    administrative or clerical services

39
Direct Charging of Administrative Costs
  • Do we explicitly budget for these costs in the
    research proposal?
  • Does the proposal include a written justification
    (why costs are necessary for project performance)
  • Is this a major project as defined in A-21 and
    Exhibit C?

40
Direct Charging of Administrative Costs
  • Are administrative and clerical costs approved by
    the Sponsor?
  • Is there a record of this for audit?
  • Effort report must reflect actual time spent
    consistent with approved proposal budget

41
Proposal Budgets
  • Cost Sharing
  • Required by Sponsor or volunteered by
    investigator
  • University commitment
  • Impact of FA rate

42
Effort Reporting
  • Definition
  • A method of certifying time spent on a research
    grant, and justifying salary expense charged to
    sponsor

43
Effort Reporting
  • Regulation
  • OMB Circular A-21, Section J.10 Compensation
    for personal services
  • J.10.b. Payroll Distribution requirements

44
Effort Reporting
  • What effort is committed in the
  • proposal?
  • Direct charged?
  • Cost Shared?
  • Commitments must be tracked

45
Effort Reporting Issues
  • Multiple sources of pay (e.g., faculty practice
    plan)
  • NIH salary cap
  • Summer salaries
  • Cost transfers not incorporated into
    certification

46
Effort Reporting
  • For personnel whose salaries are charged (or
    cost-shared) to research grants and contracts
  • Effort should be certified by responsible
    persons with suitable means of verification that
    the work was performed

47
Effort Reporting
  • Per A-21 System will provide for independent
    internal evaluations to ensure compliance
  • How does this happen at your institution?

48
Issues in Proposals
  • Facilities and Administrative Rate
  • Proposing the correct rate
  • Research, instruction, other sponsored activity

49
Issues in Proposals
  • 3. Regular rate or special location rate
  • 4. On Campus or Off Campus Rate

50
Program Income
  • Definition (A-110)
  • Gross income earned by the recipient that is
    directly generated by a supported activity or
    earned as a result of the award

51
Program Income
  • Will Award Generate Program Income?
  • What Do We Do With Income?
  • 1) Add to Award
  • 2) Use to Fund non-Federal Share
  • 3) Deduct from Total Project

52
Subcontractors
  • Proposals including subcontracts should include
  • Scope of work
  • Budget
  • Institutional commitment (OSP)

53
Subcontractors
  • Is this a Subcontract or Consultant relationship?
  • Independent line of inquiry or providing service
    or expertise?
  • Difference in FA treatment
  • Difference in ownership of IP

54
Subcontractors
  • Approval of Subcontract Invoices
  • PI should judge whether progress is satisfactory
  • Dept Administrator should determine whether subs
    costs are appropriate, within the period of
    performance

55
Issues in Proposals
  • Audit Requirements
  • Who can perform the audit
  • Audit timetable
  • Record retention
  • Notification requirement

56
Acceptance and Assignment of Financial Risk
  • Institutions authorized recipients
  • Document and report project costs
  • Institutional policies for cost overruns on
    project

57
Payment Terms
  • Advance Payments
  • Cost Reimbursement Payments
  • Progress Payments based on milestone deliverables

58
Payment Terms
  • Frequency
  • Invoices and backup documentation

59
Payment Methods
  • Letter of Credit Draws
  • Electronic Fund Transfer
  • Checks

60
Reporting Requirements
  • Contracts with unusual Reporting Requirements may
    be a problem
  • Reporting of labor hours worked
  • Detailed expenditure reporting
  • Monthly Progress Report

61
Reporting Requirements
  • Pre-Award Must Communicate the Types of Reports,
    Frequency of Reporting, Due Dates
  • Contract reporting requirements more onerous
    than grants
  • May be penalties for late reports

62
Reporting Requirements
  • Types of Reports
  • Technical/Progress (PI)
  • Patent/Invention (PI)
  • Fiscal (Sponsored Accounting)
  • Property (Asset Accounting)

63
Reporting Requirements
  • Pre-award office may be tasked with pursuing late
    reports
  • Correct report distribution info can minimize
    late reports
  • Timely reporting requires coordination

64
Performance Issues
  • Approval of project expenditures
  • Documentation of project expenditures

65
Closeout Responsibilities
  • Reaching the termination date of a project does
    not signal the end of our responsibilities
  • Institutions have sponsor requirements to fulfill
    before we can closeout the award

66
Closeout ResponsibilitiesFinancial Accounting
  • Costs must be allowable, allocable, reasonable
    and consistent with the terms of the agreement
  • Good project management over the life of the
    award will help to eliminate any problems after
    the award has ended

67
Closeout ResponsibilitiesFinancial Accounting
  • Pre-Award must communicate the with the Dept/PI
  • Is this a Fixed Price agreement or Cost
    Reimbursement
  • What is the process for an extension? Prior
    approval needed?
  • Carry-forward of funds allowed?

68
Closeout ResponsibilitiesFinancial Accounting
  • Departmental Administrator and PI must ensure
    that all costs are necessary for the performance
    of the project, incurred within the period of
    performance and charged to the project within the
    specified period (e.g. within 90 days of
    termination).

69
Closeout ResponsibilitiesReporting
  • Financial Reports Have all project expenditures
    been posted?
  • Technical Reports (PI) Submitted timely (or at
    all)? Appropriate and complete information
    (Award , PI name, title, etc.)? Proper report
    distribution?

70
Closeout ResponsibilitiesReporting
  • Invention Reports Have reports been filed,
    using appropriate forms (see Campbell Plastics)
  • Property Reports Who owns equipment, what is
    disposition, when was equipment purchased?

71
Audit Responsibilities
  • Anticipate the project will be audited
  • Audits often take place after the project is
    completed and several years after the
    expenditures were incurred

72
Audit Responsibilities OMB A-110
  • The Federal awarding agencyor any of their duly
    authorized representatives, have the right of
    timely and unrestricted access to any books,
    documents, papers, or other records of recipients
    that are pertinent to the awards.

73
Audit Responsibilities OMB A-110
  • This right also includes timely and reasonable
    access to a recipient's personnel for the purpose
    of interview and discussion related to such
    documents.

74
Audit Responsibilities
  • If records are requested and interviews are
    conducted for an audit which takes place several
    years after expenditures were incurred, will we
    be prepared to justify and support that the
    expenses are direct project costs?

75
Audit Responsibilities
  • Documentation is the key to being prepared for an
    audit
  • Are project effort reports signed?
  • Is cost sharing documented?
  • Procurement expenditures properly documented?

76
Audit Responsibilities
  • Record Retention
  • Financial records, supporting documents,
    statistical records, and all other records
    pertinent to an award shall be retained for a
    period of three years from the date of submission
    of the final expenditure report (A-110)

77
Audit Responsibilities
  • Question
  • When is the best time to prepare for an audit?
  • Answer
  • Now (and throughout the project)!
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