DEPARTMENTAL ADMINISTRATION BOOT CAMP: Research Administration for the Department Administrator

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DEPARTMENTAL ADMINISTRATION BOOT CAMPResearch
Administration for the Department Administrator
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Workshop Faculty

• Patricia Hawk
• Interim Director
• Office of Sponsored Programs
• Oregon State University
• patricia.hawk_at_oregonstate.edu
• Bruce Morgan
• Assistant Vice Chancellor
• Office of Research
• University of California, Riverside
• bruce.morgan_at_ucr.edu

• Samantha Westcott
• Grant Manager
• Division of Biology
• California Institute of Technology
• westcott_at_caltech.edu

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What do you want to take with you from this
workshop?
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Topic Areas

• Proposals
• Award Acceptance
• Award Management

• Subawards
• Closeouts
• Audits

We will also include a discussion about Cost
Transfers.
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Tasks The Work We Do

• Pre-Award
• Funding Opportunities
• Proposal Preparation, Review, Submission
• Award Review and Account Set Up
• Post-Award
• Cost Management and Account Monitoring
• Cost Transfers
• Closeout

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Guidelines The Rules We Obey

• Federal
• OMB Circulars
• Agency Guidelines
• State
• Public Institution or
• Private Institution

• Institutional
• Policies
• Procedures
• School
• Departmental
• Divisional
• Investigator

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Funding Opportunities

• Sponsors
• Government
• Foundations
• Corporate
• Donors

• Opportunities
• RFA
• RFP
• PA
• Invitation

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Discussion Finding Funding

• Theres 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.

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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?

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Proposal Preparation

• The major components of a proposal
• Budget Justification
• Abstract
• Statement of Work
• Biosketch
• Resources/Facilities
• Institutional Signoff

Research vs. Administrivia
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Benefits to Success Proposals

• The more time invested by the PI on the research
  plan, the better the proposal.
• A successful proposal
• Jobs
• Progress
• No resubmission

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Benefits to Success Proposals

• How the Departmental Administrator helps
• Correct budget
• Guideline review
• Formatting
• Up-to-date information
• Routing and Sign-offs
• Confidence
• Competence

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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

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Budgeting Details

• Identify Cost Categories Unidentified Costs
• May cause overruns on the award
• Institution shares in cost of research effort
• May require sponsor approval for rebudgeting
• Holds up post-award invoicing and financial
  reporting
• Bottom line Not in the budget? Ask.
• Personnel Costs Proposal vs. Expenditures
• Reports of time and effort are certified
• Bottom line Reporting Audits Findings

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Budgeting More Details

• Itemize Costs Correctly Follow the Rules
• 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
• Materials Supplies vs. Equipment
• A-21 threshold for equipment 5,000 (or
  institutions threshold if lower), with a useful
  life of at least 1 year
• FA rate applied to materials and supplies, but
  NOT to equipment items

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Budgeting More Details

• Travel domestic vs. foreign
• Domestic in-state or out-of-state
• Foreign allowable with prior approval, certain
  restrictions apply
• Know basis/rates for reimbursement
• Subawards vs. service agreements
• Difference between the big S and the little s
• Programmatic effort (big S) vs. goods and
  services (little s)
• Impact on FA/indirect cost recovery
• FA assessed on only the first 25K of the big
  S
• FA 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

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Budgeting More Details

• Pieces needed for Subaward
• 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
• Remember, your institution as prime recipient is
  ultimately responsible for conduct of the work
  and meeting sponsor requirements!

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Budgeting More Details

• Are costs allowable, allocable, reasonable?
• Sponsor guidelines
• OMB Circular A-21
• Institutional Rules
• Are costs direct or FA/indirect?
• Direct costs identifiable to a specific project
• Indirect costs incurred as part of overall
  operations
• Ex Direct vs. Administrative (FA) costs
• Salaries and wages of clerical/administrative
  staff generally unallowable as direct
• Exception meet the test of major project as
  defined in Exhibit C of A-21
• Application/treatment of costs should be
  consistent

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Budgeting Hints

• Project the future Look toward reality
• 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
  institutions best advantage ask every question
  to get the full cost impact from your PI

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Budgeting More Hints

• Impacts of poor planning
• Loss of direct cost funding available to the
  project
• Loss of FA/indirect cost recovery
• Disallowances

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Budgeting More Hints

• Open communication reduces
• 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

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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.

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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

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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

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Award Management

• Pre-Award Setup
• Award Review
• Set-Up
• Assignment of Costs

• Monitoring
• Cost Transfers
• Reporting
• Closeout

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Pre-Award Accounts

• Risks
• 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
• Correct assignment of costs
• Fewer cost transfers

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Award Review

• Type of Award is this an Assistance Agreement
  or a Contract?
• Assistance Agreements are either grants or
  cooperative agreements these are subject to OMB
  Circular A-110
• Contracts are subject to the Federal Acquisition
  Regulations

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Award Review

• Budget
• Reduced?
• Reduce the Scope of Work and Cost Sharing
  Accordingly
• Performance Period
• Align it with the workflow
• Accommodates pre-award costs
• Terms Reporting
• Non-Standard?
• Can we live with it?

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Award Review

• Examples of non-standard terms or reporting
• Reporting on labor hours
• Detailed expenditure reporting
• How do you, as a departmental administrator, fit
  into these requirements?

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Award Set Up

• Accounting Structure
• 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
• Align budgets to match requirements of award
• Make monitoring easier for everyone

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Lets Take a Break!
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Cost Sharing
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Cost Sharing Details

• Most institutions policies, written or not
• No cost sharing unless mandated/required by
  sponsor
• Voluntary committed cost sharing
• Faculty/key personnel time and effort stated but
  not charged to the sponsored award
• Must be tracked and reported upon
• Has negative impact on FA/indirect cost recovery
• Indirect Cost Waivers
• Does the difference between your institutions
  federally negotiated rate and the reduced rate
  you agree to accept on the award represent cost
  sharing?

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Cost Sharing and the Departmental Administrator

• The most common form of cost sharing is
  contributed effort
• Contributed effort is captured through your
  institutions effort reporting system
• Other types of cost sharing may involve
• Volunteer effort
• Equipment purchases

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Case Study

• Cost Sharing/Effort Reporting

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What is Effort Reporting?

• Salaries charged to Federal awards must be
  substantiated
• Effort reporting requirements are based on your
  institutions cost principles
• A-21
• A-87
• A-122
• 45 CFR 74, Appendix E

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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

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More Procurements

• Purchases above the small purchase limit
• Sole source vs. competitive bid process
• Source documentation typically resides with the
  departmental administrator
• Purchasing Department is typically checking the
  Excluded Parties List

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Expenditure Review

• Typical reviewable expenditures
• Food
• Late charges
• Entertainment costs
• Foreign travel
• Awards and prizes

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Monitoring Expenses

• Departmental Administrators are actively involved
  in monitoring expenses
• Do you run reports?
• Do you look at each expense?
• Do you look at expenditure reports?

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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)

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Case Study

• Allocation

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Subawards and Subrecipient Monitoring
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Key Concepts

• Subaward is an umbrella term that encompasses
• 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

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Subrecipients v. Vendors

• The substance of the relationship is the most
  important factor
• The relationship should determine the mechanism
• 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.
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Accountability

• Sponsors may
• audit subrecipients, and
• will hold the recipient accountable for the
  subrecipients performance and subaward
  management
• A subrecipients disallowance becomes the
  recipients disallowance

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Subrecipient Monitoring - Responsibilities

• Responsibility is shared across many offices,
  units and individuals
• Sponsored Programs Administration
• Contract and Grant Accounting
• Department and Principal Investigator
• Know who handles what at your institution

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Subrecipient Monitoring - Responsibilities

• Principal Investigator and department
• 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

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Subrecipient Monitoring Activities

• Review A-133 audit report or recently audited
  financial statement
• If findings, have they been resolved and how?
• Risk assessment
• Negotiated FA cost rate?
• Recipient of other federal funds?
• Designated cognizant audit agency?
• Compliance with federal requirements?
• Domestic v. foreign?

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Subrecipient Monitoring Activities

• Certifications, assurances, debarment
  suspension
• Technical and financial monitoring
• Regulatory approvals
• Compliance with subaward terms and conditions
• Reporting requirements, deliverables, etc.

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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?

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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

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Subaward Close-out

• Project performance confirm completion of the
  scope of work
• Project deliverables, timely final report
  submission
• Financial reviews review claimed costs for
• Disallowances/allowable costs
• Use of proper rates
• Fulfillment of cost sharing commitment
• Coordinate authorization of final payment with
  SPO, Contract Grant Accounting and PI

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Subawards 3 Dos and 1 Dont

• Do be proactive and facilitative
• Do know who to communicate with and when
• Do monitor subrecipients throughout the life of a
  subaward
• Dont make assumptions

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Closeouts

• Departmental administrators are actively involved
  in closeout
• Items to consider in closeout
• Adjustments need to be done in a timely manner
• Source documentation typically resides at the
  department level
• Fixed price agreements may have a residual
  balancewhat happens to that?

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Closeout

• Good project management of the life of a project
  will help to minimize problems at the closeout
  stage

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Record Retention

• Think source documentation
• Be aware of record retention requirements at your
  institution
• 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

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Audits
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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

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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.

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To Avoid an Audit or Audit Findings

• DOCUMENT, DOCUMENT, DOCUMENT!
• Attend training.
• Respond fully and timely at every opportunity
  during the audit and resolution.

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How an Inspector General Audits

• They audit in accordance with
• 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.

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How An Inspector General Audits

• An Inspector General Audits in accordance with
  criteria
• Award
• Terms and Conditions
• Proposal and Amending Letters
• Assurances
• Uniform Administrative Requirements
• Federal Cost Principles
• Laws, Regulations, and Program Guidance
• Prudent Business Person

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Cost Transfers

• Sharing our Stories

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Review

• Proposals
• Awards
• Subawards
• Closeout
• Audits

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What do you want to take with you from this
workshop?
Questions??