Post Award Management of Sponsored Projects

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Post Award Management of Sponsored Projects

• Susan Campbell, Sr. Accounting Manager
• Grants and Contracts Office
• scampbell_at_accounting.umsmed.edu
• 601-984-1058 / 601-984-1040

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Agenda

• Overview of the Responsibilities of the Post
  Award Office
• Post Award Administration of Sponsored Projects
• Effort Reporting

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What are our goals?

• Prudent stewardship of external funds
• Effective management of institutional business
• Compliance with applicable regulations
• Be a resource to faculty, staff and students

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Responsibilities of the Post Award Office

• Account Setup
• Funds Approval
• Financial Reporting/Invoicing
• Special Reporting
• Effort Reporting
• Budget Revisions
• Cost Transfers
• Review of Changes in Project Status
• Account Close Out

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Post Award Administration of Sponsored Projects

• What is a Sponsored Project?
• Any financial award (grant, contract or
  agreement) from external sponsors to conduct
  specified research, training or public service
  projects.

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Incurring Allowable CostsJust because it is in
the budget does not always mean it is an
allowable cost to the project
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Incurring Allowable Costs How do I know if a
cost is allowable?

• Reasonable
• Allocable
• Consistent Treatment
• Limitations and Exclusions
• If in doubt, please call us...

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Incurring Allowable Costs

• The primary guidance for allowable costs for our
  Federal programs is OMB Circular A-21. The link
  for the circular is...
• http//www.whitehouse.gov/omb/circulars/index.htm
  l
• This documents provides examples of allowable
  costs and guidance for making the determination.
• The Office of Research website provides links to
  policy statements on most of our sponsors.
• The link to OoR website is http//research.umc.ed
  u/

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Incurring Allowable Costs

• Direct Costs
• Non Administrative Salaries, Wages, Fringe
  Benefits, such as Principle Investigator Faculty
• Research Assistant Scientist
• Technician Post Doc
• Animals and Animal Care Per Diem
• Consultants
• Equipment
• Maintenance/Repairs -Scientific Equipment
• Page Charges/Reprints
• Freight/Other Transp. (UPS, FedEx)
• Rental of Space / Equipment
• Subcontracts
• Materials and Supplies
• Chemicals gt Gases gt Radioisotopes
• Travel

• Indirect Costs
• Administrative and Clerical Salaries, Wages and
  Fringe Benefits, such as
• Fiscal Officer Accountant
• Dept Admin Secretary
• General Purpose Equipment
• Dues and Memberships
• Meals and Refreshments
• Printing
• Postage
• Office Supplies
• Pensgtpencilsgtbindersgt
• papergtlabelsgtstaplesgtsoftware
• Telephone Charges
• Basic line chargesgtpagersgtvoicemail

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Incurring Allowable Costs

• Examples of Unallowable Costs
• Fundraising
• Lobbying
• Alcoholic Beverages
• Fines and Penalties
• Advertising (exception for patient recruitment)
• Honoraria
• Entertainment

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Incurring Allowable Cost

• Notes on specific items of cost
• Travel - must be necessary for the conduct of the
  sponsored project
• All travel must follow UMC travel policies (i.e.
  coach fares, prior approvals, etc.)
• Federal policy requires that you use U.S. flag
• carriers, whether or not the U.S. carrier is
  more
• expensive than a foreign carrier. Cost is not a
  
• consideration.
• UMC policy is persons charging travel to a
  sponsored project must be directly working on
  that project Justifications are required for
  anyone not certifying effort to the project.

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Incurring Allowable Cost

• Equipment
• All general purpose equipment must be adequately
  justified. in writing
• Equipment purchases exceeding 25,000 must be
  reviewed by Grants Office and possibly the
  Sponsor
• No major equipment in last year of grant/contract
• Consultants / Professional Services
• Must be practical - cost efficient as opposed to
  using direct employees
• Necessity of contracting
• Qualifications of the individual / concern
  providing service
• Adequacy of the contractual agreement
• Some agencies have limit to amount that can be
  paid to a consultant on a daily basis

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Cost Transfers

• Mayo Foundation Settles Allegations, Pays 6.5
  Million to Government
• ( Source Federal Grant News / NACUBO June 2005
  and press release document _at_ http//postbulletin.t
  ypepad.com/honk/2005/06/us_vs_mayo_foun.html )
• Allegations Include
• Mischarging of direct costs between numerous
  federally
• funded research grants to avoid overspending
• Shifting expenses from overspent grants to
  underspent
• grants
• Misrepresented compliance with the terms and
  conditions of the grant awards by submitting FSR
  and drawing federal funds.
• Nearly half of cost transfers were untimely,
  inadequately documents and/or misallocated

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Cost Transfers

• What is a cost transfer and what is UMC policy?
• Transfers of costs to any sponsored project that
  represent corrections of clerical or bookkeeping
  errors must be made within 90 days. All
  transfers must be supported by documentation that
  fully explains how the error occurred and
  certification of the new charge by the principle
  investigator. Transfers of costs from one budget
  period to the next or from one project to another
  to solve funding problems or other reasons of
  convenience are not allowable.

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Which transfers should be of concern?

• Transfers on Federal Project
• Transfers that move charges more than 90 days of
  the original charge
• Transfers to Federal Projects at the end of a
  project

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Which transfers should be of concern?

• Transfers with inadequate explanation (i.e. To
  correct error or to charge correct project)
• Transfers between Federal Projects when an
  overdraft is involved
• Salary transfers (Retroactive PAR)

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Budget Revisions

• Budget revisions are required for most
• sponsored projects. (AHA and subcontracts)
• Change beginning 7/1/05 - budget revisions for
  equipment purchases on modular awards are no
  longer required. Any general purpose equipment
  regardless of cost - or - scientific equipment
  costing more than 25,000 still requires
  justification and approval, but no budget
  revision form.

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Changes in Project Scope

• A change in the specific aims approved at the
  time of the award
• Substitution of one animal model for another
• Shifting emphasis of research from one disease to
  another
• Transferring work to a third party
• Change in key personnel
• Significant re-budgeting
• Incurrence of patient care costs not originally
  approved

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Changes in Project Scope

• If you have a change in project scope during a
  budget period contact the Grants and Contracts
  Office for instructions
• These changes require business office approval
  prior to submission of request
• to sponsor.
• NOTE First time no cost extensions on NIH
  projects are now requested through NIH Commons -
  Office of Research coordinates

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Financial Monitoringof Sponsored Projects

• It is the responsibility of the PI to ensure that
  all charges are appropriate.
• The Grants and Contracts Office prepares
  financial reports and/or invoices for most
  sponsored projects.
• Exception.. Clinical Trial Agreements.. The PI
  / study coordinator prepare invoices.

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Financial Monitoring

• The PI should review all invoices and financial
  reports.
• UMMC requires PI signature on all financial
  documents prepared for sponsored projects.
• Monthly budgets statements are sent to the
  PI/dept. Questions should be discussed with
  Grants and Contracts

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Effort Reporting

• Why do I have to complete this report?
• OMB Circular A-21, J-10c(2) Compensation for
  personal services, after-the-fact activity
  records to confirm appropriateness of charges

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Who has to complete an effort report?

• Anyone who has effort pledged to or is paid from
  federally sponsored projects or other sponsored
  projects

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Effort Reporting Form
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How do I fill out this form?

• Verify accounts identified as a pay source
• What type of activities are you working on?
• Is there a UMC account number assigned to those
  activities?
• How much effort have you committed to various
  projects?
• Is there someone working on your project that is
  not getting a report?
• What if the employee has left the department or
  UMC during the month?
• Sign and date the report

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• General Info to Consider for Effort Reporting
• Charges for S/W must reflect actual effort
  expended, not necessarily what was budgeted
• Charges for S/W must be based on documented
  Institutional Base Salary (what is in the
  employment contract)
• Someone with first hand knowledge of work
  activities must sign the report (i.e. the
  employee, PI or designee)
• Payroll can not be retroactively charged to a
  sponsored project more than 90 days
  back...unless effort has been documented for the
  entire time
• Private practice activities should not be
  included on report
• Measurable contribution of key personnel is
  defined as 1
• Prior approval is still required if effort
  decreases by 25 or more in a no-cost extension
  period

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Common Problems.

• Invalid account numbers
• Omission of account numbers / activities
• Reporting effort under wrong category
• Reporting effort to faculty research enhancement
  program pay sources (28007)
• Returning forms with no effort or incorrect
  percentages written in (Percent effort100)
• Report not signed and dated
• Report not turned in timely

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Florida International University Settles Effort
Reporting Allegations - 11.5 Million

• (Source Federal Grant News - March 2005 and
  NCURA 2005 spring meeting)
• Add FIU to a growing list of higher
• education institutions that have had audit
• findings and settlements with respect to
• effort certification. On February 10, the
• universitys trustees voted to repay 11.5
• million to settle the issues. The university
• also agreed to forego another 1.7 million of
• additional costs.

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Note for FY04/05Effort Reports

• All effort reports for the period
• July 1, 2004 through June 30, 2005 are due by
  August 15th

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Questions on Effort Reporting
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Close Out of Sponsored Projects

• At the end of the budget and/or project period
  the Grants and Contracts Office will prepare a
  final accounting for the sponsor
• Exception. Clinical Trials. We do not know it
  is over until you tell us!

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Things to Consider When Closing Out a Sponsored
Project

• Submit Final Technical Report to Sponsor
• Change Employee Pay Source via PAR
• Clear Out All Outstanding Purchase Orders
• Check Budget Statements for Charges After the End
  of the Project
• Resolve Any Over-expenditures or Unallowable
  Charges

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Close Out of Clinical Trial Accounts

• Please Notify the Appropriate Compliance Office
  AND the Grants and Contracts Office when the
  Study is Complete

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Close Out of Clinical Trial Accounts

• To Utilize Residual Funds from Industry Sponsored
  Projects you Must Provide the Grants and
  Contracts Office with
• 1) A copy of the notification letter to/from the
  IRB stating study has been closed
• 2) Documentation from sponsor that study is
  complete
• 3) A memo from the PI certifying that all
  expenditures / obligations related to the project
  have been finalized
• 4) If the account is going to be renamed (for
  example.. Dept of XYZ Research and Development
  Account) then a Request for Account form will
  also have to be prepared and approved.

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Grants and ContractsContact Information
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Grants and Contracts Office
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UMMC Grants Policy Manual

• The Accounting manual is on the UMMC Intranet.
  Go to Intranet home page - Support, then
  Comptrollers Office
• The direct link to the Grants Information is
• http//accounting.umc.edu/Departments/depts_Grants
  Contracts.html