Keys to Successful Sponsored Award Processing

Keys to Successful Keys to Successful Sponsored Award Sponsored Award

ProcessingProcessing

Program for Sponsored Award Faculty and Staff

Fall 2008

Neta FernandezAncelmo (Sam) Encinias

AgendaAgenda

• Whose idea? • Various Players• Proposal cycle• Award cycle• Basics• Cost Accounting Standards (CAS)• Cost Share and Other Costing

Basics• Audits• Questions

Whose Idea Was This?

Began with various committeerecommendations:

• Grant and Contract Process

• F&A Recovery

• Disclosure Statement

Unanimous Recommendation

• Mandatory (and ongoing) training

• Reduce duplication of CAS justifications in budgets

• Streamline grant and contract process

Other Workshops• Cost Accounting Standards (CAS)

• Cost Sharing

• Export Control

• Others, as requested

Various Players

Who is Research CenterWho is Research Center

• Reports to the college Associate Dean or Director• Available to PI’s for questions and

info• Assist with proposal• Questions on

purchases/expenditures

Who is OGC?

Reports to VPR ~10 research administrators Submits all proposals Negotiates with agencies Provides assistance/training Provides authorized signature

for Board of Regents Responsible for close out

Who is Sponsored Projects Accounting (SPA)? Reports to Senior Vice President for

Business, Finance, and HR

Creates indexes

Invoicing/billing

Review & process financial trans-

actions, ensuring compliance with

federal, agency and NMSU regulations

Proposal Cycle

Sam Encinias

How to do Proposals?How to do Proposals?PI writes proposal

PI works with RC on budget and assembling proposal as required by Sponsor

RC submits proposal to OGC

OGC reviews, approves, submits proposal

Proposal DeadlinesProposal Deadlines 5 Days before deadline to OGC

for all Electronic Proposals that must be submitted through the Grants.gov on-line portal

48 Hours before deadline to OGC for Non-Grrants.gov proposals

Allow extra lead time for Complex Proposals

Complex ProposalsComplex ProposalsKey is the RFPNew Sponsor with Unique

GuidelinesWork is InterdisciplinaryIncludes Partners – SubcontractorsCenter Grants – Multi YearCost Share or In-kindForeign Countries – Export Controls

Keys to a Successful Keys to a Successful ProposalProposal Start Early

Team Effort

Cover all your bases up front

YEA – Received Award

Neta Fernandez

OGC receives award OGC reviews and negotiates OGC prepares award packet OGC sends packet to SPA SPA creates index OGC and RC notified of index#

Finally…PI begins research

Award Cycle

Let’s Discuss the BasicsLet’s Discuss the Basics

Definitions of Agreement

Grant: more flexible than contract; team oriented; deliverables normally consist of report

Contract: issued by external sponsors for detailed statement of work with final or milestone deliverables

Definitions of AgreementDefinitions of Agreement

Cooperative Agreement:

similar to grant but has statutory

criterion that anticipates substantial

agency involvement

Definitions of Agreement

Gift: a donation, no deliverables; all gifts processed through the Office of the Vice President for University Advancement

* Colleges sometimes have one specific person who deals with Advancement

Types of Awards

• Fixed Price

• Cost Reimbursable

Fixed Price

Grant or contract for which one

party pays the other party a pre-

determined price, regardless of

actual costs, for services rendered

* More common on contracts

Cost Reimbursable

Grant or contract where one party

pays other party for full allowable costs

incurred during project. Based on actual

costs incurred including direct and

indirect costs.* Common on grants

Cost Accounting Standards (CAS)

“The

Rule”

Sponsored Award Costs

There are two ways to charge toa sponsored award:

• Direct costs

• Indirect costs

Cost Accounting Standards (CAS)

• Created as act of Congress, 1971

• Applied to universities in 1996

• Promoted greater standardization of costs

• Goal to tighten rules on allowability/ allocation

Direct Costs

OMB Circular A-21 definition:

Those costs that can be specifically

identified to the cost objective

with relative ease and a high degree

of accuracy

Examples of Direct Costs

• Salaries and wages including fringe

• Non-office supplies

• Subcontracts

• Animal use fees

• Travel related to project

OMB Circular A-21 definition:

Costs that are incurred for common or joint objectives and therefore, cannot be identified readily and specifically with particular sponsored project, an instructional activity, or any other institutional activity

Facility and Administrative(F&A or Indirect Costs)

Examples of F&A Costs

• Operation and maintenance of buildings

• Library costs

• Administrative office supplies

Charging Indirect Costs as Direct Costs

• Must be required by scope of work

• Cost can be accurately identified / allocated to project

• Must be unique requirement and be justified

• Evaluated on case-by-case basis

Is it Acceptable?

For example, office supplies are consideredunder F&A costs. If you can show that the office supplies are an unlike circumstance or are excessive for this project, you can write a justification and get approval for charging as a direct cost.

Office Supplies Example

Program is to promote AIDS

Awareness on campus. Requires

unusually large amount of supplies to

prepare brochures and educational

training materials for workshops

Supplemental Compensation

For exempt staff and faculty to be paidsupplemental compensation, the workmust:

• cross departmental lines or be at remote site AND• be performed in addition to regular workload

Supplemental Compensation

• Must have agency approval

• Must have approved CAS justification

• Must comply with NMSU policy and procedures

Questions?

Role of PI

Sam Encinias

Get Started

• Three general phases to funding cycle:

-- Proposal Devel & Submission

-- Project Administration

-- Project Reporting & Closeout

• Hopefully, Reporting & Closeout is not

“forever” but leads to follow-on or

subsequent grant

Proposal Development and Submission

Proposals have 3 general areas:

• Technical Proposal (your ideas)

• Management Proposal (who will do the work, does NMSU have right facilities, are protocols to conduct work in place, do we need subcontractors, etc)

• Cost Proposal (who will pay for what, are costs proper, do they track with technical needs of work, etc)

Provide a copy (ASAP) of Request for Proposal (RFP) to research center

Proposal Award Form (PAF)

Proposal Development and Submission

Management ProposalManagement Proposal

• Develop staffing plan◦ Faculty, students,

professional staff◦ AY and summer loads◦ Subcontractors?

• Ensure that NMSU follows proper protocols for test subjects, laboratories, and research materials (as applicable)

• Ensure everyone involved is eligible to work on the project

Cost ProposalCost Proposal

• Cost Proposal◦ Look for restrictions on

funds, cost share requirements, etc. in RFP

• Budget expenses according to CAS guidelines; justify expenses as needed for NSMU and/or RFP

• Supply documentation for cost sharing or F&A caps

Project Administration

Project Administration Stages:

• account/project setup

• day-to-day administration

• project reporting

Day-to-Day Administration

• Personnel

-- allocate, monitor, track level of effort

-- complete effort certifications (6 mo)

-- record timesheets in timely manner

• Property

-- if property is purchased under

grant, track property as part of

NMSU inventory list

Day-to-Day Administration

Financial Responsibilities:

• ensure cost sharing is documented and met• expend funds per approved budget• initiate, monitor, and approve expenditures

for subawards• review/validate expenditures on BANNER• ensure travel expenses follow agency

requirements and NMSU allowed costs

Day-to-Day Administration

Purchases:• Can use Purchase Order or Procurement

Card• Vendors must be approved and “in system”• Use “account codes” to map purchase items

to budget categories• PI initiates purchase and gets approval at

department/college/unit level for

appropriateness and funds available** PI responsible if purchases are not appropriate

Project Reporting

• Technical Reports -- prepare project Final Report and any Intermediate Reports according to terms and conditions from agency -- disseminate project results according to proposal plan (conference proceedings, journal articles, etc) and acknowledge grant

• Assist research center in final reporting of financial matters, inventions, inventory, etc

More Basics

Cost Sharing

Definition:

Portion of project costs not borne by sponsor

Cost SharingTwo types of cost sharing:

• Mandatory – required by agency or statute as condition of award

• Voluntary – NOT required by agency; cost sharing is not required but university funds part of cost of research

Cost Sharing

• Charge full F&A, unless

capped by agency

• Treated as cost share

Cost Sharing

If not charging full F&A and not

capped – MUST have VPR approval

Voluntary cost share will only be approved

in very rare cases such as when it is

considered a proposal review criteria and

is stated as such in the RFP

Cost Sharing

Terminology may vary among agencies:

• cost sharing

• matching funds

• in-kind

Cost Sharing

National Science Foundation has

policy stating voluntary cost share

cannot and will not be considered

in the granting of the award

Effort Reporting

Federal Government requirement

PI must sign and certify the percentage

of effort twice a year Timesheet personnel (hourly) sign

timesheet as certification

Business Procedures Manual

• Outlines procedures for conducting

business processes at NMSU

• www.nmsu.edu/~boffice (under Resources)

Property Guidelines

• All property (equipment) purchased will be tagged

• Physical inventory conducted annually

PI is responsible for knowing the Location and condition of equipment

Program Income

OMB Circular A-110 definition:

income generated from a project

financed by a grant or contract

Program Income

Can be revenue obtained from:

• conference fees

• sale of videos

• sale of books

Program Income

Federal regulations provide followingguidelines for treatment of program income:

• Use to further program objectives*

• Use to finance non-federal share of project

* Default application for research projects

Compliance and Audits

Neta Fernandez

Special Compliance TopicsSpecial Compliance TopicsMonitored Thru CommitteesMonitored Thru Committees

Compliance Committeesand Issues

• Conflict of Interest

• Institutional Review Board (human subjects)

• Institutional Animal Care and Use Committee (animal subjects)

Compliance Committeesand Issues

• Institutional Biosafety Committee

• Supplemental Compensation

• Export Control

Conflict of Interest Definition

• Research where it appears researcher may have significant financial interest that could directly/indirectly affect the design, conduct, or reporting of research activities

• Or the researcher’s situation could directly and significantly compromise his/her professional commitments to NMSU

Conflict of Interest Examples

• Issuing subaward to spouse/significant other

• Purchasing supplies/equipment from company that relative/close friend owns

• Accepting gratuities or gifts from private organization that may be interpreted as attempt to influence

Conflict of Interest Procedures

• PI required to fill out and submit a Disclosure of Significant Financial Interest at annual evaluation

• PI required to submit new form when new interests are acquired

Conflict of Interest Conflict of Interest CommitteeCommittee

GOAL is to resolve completely or develop a plan to manage

Note: COI problems can cause PI to pay back agency out of personal

funds

Institutional Review Board (IRB)

• NMSU is required by federal regulations to review research involving human subjects

• Must have IRB approval before PI actually begins research

Institutional Animal Care andUse Committee (IACUC)

• NMSU is required by federal regulations to review research involving animal subjects

• PI required to get IACUC approval for any use of vertebrate animals – including research, teaching or testing

• PI must get IACUC review and approval in advance

Institution Biosafety Committee (IBC)

• Provides guidelines for research or academic programs involving biological agents

• Researchers must receive IBC approval before beginning work

Export Control

• Federal laws to protect items, technical data, and information important to U.S.

• More important during times of war or heightened security*

*Protect national security

What is an Export?

• Any oral, written, electronic or visual disclosure, transfer or transmission outside the US to anyone, including a US citizen, of any commodity, technical data, technology, or software

• Transfer of a controlled commodity, technology, or software to a non US entity wherever located

Foreign Students/Scientists

• Large presence of foreign students and scientists at NMSU increases the chance of transferring knowledge to other countries.

Note: Export Control laws can restrict use of foreign students/scientists on research

University Exemption

Exemption for universities:

• fundamental research

• open publication rights

• does not involve satellite

Civil penalties up to $500,000 each violation

Criminal penalties up to $1,000,000 each violation

Imprisonment up to 10 years

OR BOTH

Penalties and Fines

Dr. Horan

Intellectual Property/Tech Transfer

• Patent rights retained by university

• Government receives license to practice

• Universities to share royalties with inventors

Bayh Dole Act

• Signed prior to beginning of research project

Intellectual Property Agreement

Director of Intellectual Property

and Technology Transfer

Maureen Camunez 6-5398

Questions? Contact:

Review of Activity - Audits

Auditors

As recipient of federal funds, NMSU issubject to frequent reviews by various groups of auditors

Purpose of Audits

For sponsored awards:

• ensure compliance • ensure achievement of stated goals of award

Groups of AuditorsGroups of Auditors

External -- federal -- state -- agency auditors

Internal -- Audit Services at NMSU

Consequences of Audit Findings

Unfavorable outcomes can result in:

• Disallowances of claimed costs with refund to sponsor

• Termination of agreement

• NMSU no longer receiving awards from that agency

Notification of Audit Findings

• Board of Regents

• State Auditor’s Office

• Federal Clearinghouse

• Sponsoring Agency

• NMSU Audit Services will follow up on findings

Important Note to PIImportant Note to PI

If contacted by agency or the Inspector

General’s Office for any agency regarding a

Review –

CONTACT CONTROLLER’S OFFICEIMMEDIATELY!! 646-2432

How Can You Protect Yourself,How Can You Protect Yourself,Your Staff, and NMSU?Your Staff, and NMSU?

• Understand the policies and regulations that apply to your project

• If program activities deviate from award, get sponsor approval in writing

• If you or someone close to you will receive money from an award, file appropriate disclosures and get

approval in advance

How Can You Protect Yourself,How Can You Protect Yourself,Your Staff, and NMSU?Your Staff, and NMSU?

• Do not charge a grant or contract for large

amount of supplies and/or equipment toward end of project.

• Be cautious when using funds from one grant to support activities on another grant.

How Can You Protect Yourself,How Can You Protect Yourself,Your Staff, and NMSU?Your Staff, and NMSU?

• Track your time and charge it accordingly

• Monitor financial activity on your account

• When in doubt, ask for help!

OGC Contact InformationOGC Contact InformationPhone: (575) 646-1590

FAX (575) 646-2020

Email: ogc@nmsu.edu

Web:http://research.nmsu.edu/ogc.html

Compliance Requires Compliance Requires TeamworkTeamwork

All those involved must work together as

a team

Questions?

Thank you for all your Thank you for all your attention!attention!