REGION 1 SPRING MEETING

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REGION 1 SPRING MEETING

• Steering Clear of the Jaws of
• Non-Compliance
• Docking Safely and Clearing Customs Award
  Closeout and Audits
• Presented by
• Marisa Schasel, Associate Director, Brown
  University

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Docking Safely Clearing Customs
A variety of docking scenarios exists. Knowing
how to tie up to something like this requires a
through knowledge of knots and line handling.
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Docking Safely Clearing Customs

• Docking Safely and Easily
• Easy does itwork with the tidal currents and
  wind, visualizing what you will do before you do
  it, and use the throttle for starting or stopping
  momentum, not for brutal force.
• Tie up to windward or up-current pilings first.
• Prepare crew for your maneuvers by telling them
  in advance how you plan to enter or leave dock
  and what they will need to do.
• Get lines, bumpers, and boat pole out of lockers
  and ready before they are needed.
• When coming into an unfamiliar marina, radio
  ahead to ask for wind, current, tidal range
  information, and directions to your slip.
• Just like a suburbanite who might need a big city
  passerby to help in parallel parking, don't be
  afraid to ask the marina or a dockside resident
  for a hand just remember that boats don't turn
  like cars!

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Docking Safely Clearing Customs

• Some facts you need to know about Clearing
  Customs
• On returning from an international trip, you must
  pass through "Customs" and may be required to
  provide the U.S. Customs Service with a list of
  the items you purchased or were gifted outside of
  the U.S., including the costs of the items.
• You must "declare" these items, meaning  that
  when you are re-entering the US, you must report
  all goods you are bringing back that you did not
  have when you left the United States.
• Duty is the amount of money you must pay the
  government for items you are bringing home which
  were purchased in another country.
• Duty is a tax collected only on imported goods.

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Docking Safely Clearing Customs

• You will find it easier and faster to fill out
  the Declaration Form if you do the following
• Keep your sales slips from purchases made abroad
  in case you are asked to verify the cost of any
  of the items that you listed on your customs
  declaration.
• When packing, try to group the items you will
  need to declare in the same luggage, in case you
  need to remove them for inspection
• Read the signs in the Customs area. They contain
  helpful information about how to clear Customs.
  If you need help clearing Customs, please do not
  hesitate to ask the Customs inspectors for
  assistance
• Under U.S. law, Customs inspectors are authorized
  to examine luggage and cargo. Under the search
  authority granted to Customs by the U.S.
  government, every passenger who crosses a U.S.
  border may be searched

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Docking Safely and Clearing Customs Award
Closeout and Audits

• What we will discuss today
• What are the roles and responsibilities of the
  PI, Department Administrator and OSP/Central
  Office in preparation and submission of reports,
  closeout of awards, and audits?
• What are reporting requirements University and
  Sponsor ?
• What considerations are made prior to award close
  out?
• No cost extensions carry forward of unobligated
  balances cost sharing commitments
• What types of audits are sponsored projects
  subject to?
• Who is responsible for financial record retention
  for sponsored projects?

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Award Closeout
• Considerations prior to closeout
• Financial Reporting
• Other Reporting Requirements
• Audits
• Record Retention

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Actions To Consider Prior To Closeout
• No Cost Extensions
• Unobligated Balances
• Cost Sharing Commitments
• Outstanding Obligations
• Subcontractor Payments

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Requesting No-cost Extensions
• Prior to the project end date, the PI determines
  that the objectives of the sponsored project
  cannot be met within the award period and that
  additional time is needed.
• It is the responsibility of the PI and Department
  Administrator to be familiar with federal and
  non-federal sponsor requirements relating to
  no-cost extension requests.

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Most federal government sponsors do not require
  prior approval i.e. permit the University to
  internally approve one twelve-month extension.
• The FDP matrix provides agency guidelines
  http//www.nsf.gov/pubs/fdp/fdpmatrix.xls
• Brown University requires completion of
  University Prior Approval System (UPAS) form.

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Case Study No Cost Extension
• Dr. Poors NIH grant is in its final year and is
  not being renewed. The PI is reviewing the draft
  final financial report and notices there is an
  unobligated balance of 100,000. Dr. Poor
  decides to request a no-cost extension to
  complete the research.
• What factors need to be considered?

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Factors to consider
• What are NIH regulations related to no cost
  extensions?
• Are there specific award terms related to no cost
  extensions?
• Why is a request for an extension needed?
• Why is the request being made after the end date
  of the award?

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Docking Safely and Clearing Customs Award
Closeout and Audits

• NIH policy states that the grantee may extend the
  final budget period of the previously approved
  project period one time for a period of up to 12
  months beyond the original expiration date shown
  in the NGA if
• no additional funds are required,
• the projects originally approved scope will not
  change, and any one of the following applies
• Additional time beyond the established expiration
  date is required to ensure adequate completion of
  the originally approved project.
• Continuity of NIH grant support is required while
  a competing continuation application is under
  review.
• The extension is necessary to permit an orderly
  phase-out of a project that will not receive
  continued support.

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Docking Safely and Clearing Customs Award
Closeout and Audits

• The fact that funds remain at the expiration of
  the grant is not, in itself, sufficient
  justification for an extension without additional
  funds.
• Different sponsors may have specific policies for
  the time frame in which a no-cost extension
  should be requested and how the request should be
  made.
• The general rule is that a no-cost extension
  should be forwarded to the sponsor well in
  advance (at least 60 days) of the project
  expiration date.
• NOTE Any additional extension beyond the
  one-time extension of up to 12 months requires
  NIH prior approval.

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Unobligated Balances
• Most sponsors allow for the automatic
  carry-forward of unobligated balances between
  budget periods.
• Understand sponsor requirements and the terms and
  conditions of the award.
• The FDP matrix provides agency guidelines
  http//www.nsf.gov/pubs/fdp/fdpmatrix.xls
• For NIH awards where the reported carryover of
  unobligated balances is in excess of 25 of the
  award, the carryover amount may be subject to
  sponsor review and approval and may require
  justification.

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Docking Safely and Clearing Customs Award
Closeout and Audits
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Docking Safely and Clearing Customs Award
Closeout and Audits
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Docking Safely and Clearing Customs Award
Closeout and Audits

• Cost Sharing
• Mandatory Committed
• Required by the sponsor quantified in proposal
• Must be captured, documented, and included in the
  FA rate calculation
• Voluntary Committed
• Not required by the sponsor quantified in
  proposals budget or award
• Must be captured, documented, and included in the
  FA rate calculation

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Factors to consider
• Have cost sharing commitments been met?
• Subcontractor cost sharing commitments.
• Is appropriate supporting documentation on file ?
• What if you have not met cost sharing commitment?

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Cost Sharing of Effort
• Brown University provides Department
  Administrators with certification forms for
  salary cost sharing (mandatory and voluntary
  committed).
• Voluntary committed cost sharing, is not included
  in the award terms and conditions it must be
  tracked at the department level.
• PIs must review and approve this certification.

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Outstanding Obligations
• Communicate with PIs and other project personnel
  to ensure expenditures have been reviewed and
  processed.
• Pending subcontractor invoices

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Docking Safely and Clearing Customs Award
Closeout and Audits

• FINANCIAL REPORTING
• AND
• OTHER REPORTING REQUIREMENTS

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Docking Safely and Clearing Customs Award
Closeout and Audits

• What are our roles and responsibilities
• for the closeout of awards and related
  preparation and submission of
• required reports?

NOTICE OF GRANT
AWARDCENTER GRANT
Issue Date06/24/2004Departmen
t of Health and Human ServicesNational
Institutes Of Health
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Docking Safely and Clearing Customs Award
Closeout and Audits

• Department PI
  Administrator Office of Sponsored
  Projects

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Typical final reports required for sponsored
  projects include
• Financial reports
• Technical/Programmatic reports
• Report of Inventions
• Final Inventory of Equipment

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Depending on sponsor and award terms and
  conditions other reports may be necessary, such
  as
• Report of cost sharing
• Small Business Subcontracting Plan
• Termination Notices (NIH Training grants)

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Docking Safely and Clearing Customs Award
Closeout and Audits
For awards under SNAP, an FSR is required only at
the end of a competitive segment rather than
annually. The FSR must be submitted within 90
days after the end of the competitive segment and
must report on the cumulative support awarded for
the entire segment.
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Docking Safely and Clearing Customs Award
Closeout and Audits

• Financial Closeout Policy and Procedures
• Review of Brown Universitys Policy

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Docking Safely and Clearing Customs Award
Closeout and Audits
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Docking Safely and Clearing Customs Award
Closeout and Audits
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Docking Safely and Clearing Customs Award
Closeout and Audits
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Docking Safely and Clearing Customs Award
Closeout and Audits
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Docking Safely and Clearing Customs Award
Closeout and Audits
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Docking Safely and Clearing Customs Award
Closeout and Audits
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Docking Safely and Clearing Customs Award
Closeout and Audits
Reminder

• Technical/Programmatic Reports
• Department
• PI Administrator
  OSP

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Report of Inventions
• Most sponsors require that discoveries and
  inventions be disclosed to the sponsor upon
  conception.
• OSP or the sponsor will notify the PI when
  invention reports are required and will supply
  the necessary forms (See example of DHHS Final
  Invention Statement and Certification on next
  slide)
• At Brown it is the responsibility of the PI to
  report an invention to the Brown Technology
  Partnerships at the earliest possible time to
  avoid premature public disclosure
  http//www.research.brown.edu/btp/index.php.

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Docking Safely and Clearing Customs Award
Closeout and Audits
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Docking Safely and Clearing Customs Award
Closeout and Audits

• Final Inventory of Equipment
• Some federal contracts and grants require a final
  inventory of equipment purchased, fabricated or
  furnished by the sponsor during the period of the
  project.

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Small Business Subcontracting Plans
• A small business subcontracting plan must be
  developed and approved prior to the issuance of
  federal contracts 500,000 or greater.
• Reports required
• SF-294 Small Business Subcontracting Report for
  Individual Contracts - completed semi-annually
  and
• SF-295 Summary Subcontracting Report - completed
  annually

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Key points to remember
• Sponsored project reporting is a joint effort
  between the PI, Department Administrator, and
  OSP.
• Failure to submit final reports in a timely
  manner may jeopardize subsequent funding for both
  the individual PI and/or University.
• At Brown University departments are responsible
  for any sponsored project over expenditures at
  award close-out.
• Evidence of submission of technical/programmatic
  reports must be provided to OSP.
• Our signatures provide certifications that all
  information is accurate and expenditures incurred
  support the sponsored project.

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Docking Safely and Clearing Customs Award
Closeout and Audits

• What are our obligations after award close-out?
• The right of the federal awarding agency to
  disallow costs and recover funds on the basis of
  a later audit or other review.
• The obligation of the recipient to return any
  funds due as a result of later refunds,
  corrections, or other transaction.
• A-133 Audit requirements.
• Property management requirements of A-110
  sections .31 through .37.
• Record retention requirements of A-110 section
  .53

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Audits
• As recipients of federal sponsored project funds,
  the University is subject to the annual audit
  requirements of OMB Circular A-133 and the
  Internal Revenue Service.
• Federal Agency Specific Audit
• Sponsor Audit Award Specific
• Internal Audit Office performs annual audits.
• The primary purposes of the internal audit
  process are internal control evaluation, internal
  policy compliance, regulatory policy compliance,
  and process improvement.
• All sponsored projects audit requests must be
  coordinated with OSP. The Department
  Administrator and PI must be available to assist
  OSP with responses to auditors questions

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Start preparing for the audit the day you submit
  the proposal.
• Audits test for
• Unallowable Costs
• FA Rate and Calculation
• Timeliness of Reports
• Subrecipient Monitoring

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Documents Required for Audits
• Copy of Agreement
• Proof of Salary Approval
• Copies of invoices
• Cost Sharing Documentation
• Effort Reports

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Documents Required for Audits (continued)
• Subawards
• Copy of awards
• Copy of report or deliverables
• Copy of approved invoices
• Approved rates for service centers/recharge
  centers

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Keys to a Successful Audit
• Organized files
• Complete documentation for expenses
• Appropriate approvals
• Audit trails
• Knowledge of policies and regulations

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Record-Keeping and Record Retention
• Grantee financial records, supporting documents,
  statistical records, and all other records
  pertaining to the grant award must be retained
  for a period of at least three years from the
  date of submission of the annual financial report
  (45 CFR 92.42, or 45 CFR 98.90). Exceptions to
  this are
• If any litigation, claim, financial management
  review, or audit is started before the expiration
  of the three-year period
• Records for real property and equipment acquired
  with Federal grant funds must be retained for
  three years beyond the date of final disposition
• Control guidance and best practices for ensuring
  the integrity of University transactions and
  records can be found at the Office of Internal
  Audit at http//www.brown.edu/Administration/Inter
  nal_Audit/guidance/index
• Departments are responsible for maintaining
  original documentation for all purchasing card
  transactions, supporting documentation for
  electronic transactions, and recharge center and
  service center logs. Please note that record
  retention for these two areas is seven years as
  prescribed by the University.

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Docking Safely and Clearing Customs Award
Closeout and Audits

• Questions?

Marisa_Schasel_at_brown.edu [phone]