1 Grants Management, Financial Responsibilities, and Research Related Issues Carol Hillmer Assistant Dean CALS Research Division November 19, 2003

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Grants Management,Financial Responsibilities,and Research Related Issues

Carol HillmerAssistant Dean

CALS Research Division

November 19, 2003

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Responsibilities Individuals authorized to sign transmittals

and other actions on behalf of their Department/Center need to thoroughly review and understand what they are signing

Departmental/Center signatories are responsible for the requests, proposals, documents, etc., which they sign and forward through campus

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Responsibilities continued

CALS Research Division will not approve requests that are unclear, inaccurate, or incomplete

Research and Sponsored Programs is delegated signature authority (authorized official) by the Board of Regents for proposals, agreements, contracts, etc. related to extramural support activities of the University

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Principal Investigator is responsible and accountable to the grantee for the proper conduct of the project or activity

Authorized official is held responsible by the sponsor to assure that the institution will meet the obligations

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Each of us is a representative of the UW, accountable to the State of Wisconsin, and ultimately responsible for assuring efforts of good stewardship

Communications – keep departments/ centers, college, and RSP in the loop

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Applications, Agreements, etc. Applications are submitted by the

University of Wisconsin-Madison on behalf of the Principal Investigator

Proposals (pre-, full, electronic) all must route through the department, college, and RSP for review and approval prior to submission to an agency/sponsor

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Awards Awards are accepted by the University of

Wisconsin-Madison and assigned to a Principal Investigator

Terms and conditions may be negotiated and must be fully accepted prior to an award number being issued

Protocol approvals must be approved prior to an award number being issued

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Personnel Issues Principal Investigator must be

payrolled OR cost shared on the grant – effort must be shown and the level must be reasonable

Principal Investigator is responsible and accountable to the grantee for the proper conduct of the project or activity and for overall award management

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Personnel Issues continued

Key personnel are individuals who contribute in a substantial way to the scientific development or execution of the project Includes PI and collaborator(s) May include researchers/scientists Does not include students

(undergrads, grads, or post-docts) or general support staff

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Personnel Issues continued Consultant

provides professional advice or services on the basis of a written agreement for a fee

expertise or skills add value to the project not an employee

Administrative and Clerical support salaries are normally not allowable costs on grants – they are a component of our Indirect Cost Rate

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Personnel Issues continued

Fellowship appointments are as Pre-doctoral or Post-doctoral Fellows

Post-doctoral research appointments are as Research Associates

Graduate student research appointments are as Research Assistants

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Personnel Activity Reports PARs represent an after-the-fact

certification of an individual’s actual effort

Employees that are payrolled from or cost-shared toward a federally-sponsored project are required to complete a PAR

Total effort cannot exceed 100%

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PARs continued Problem – Employees that are cost-

shared toward a non-federally-sponsored project are NOT captured on the PAR system

Problem – PARs are on occasion inaccurately certified which may be interpreted as an act of fraud

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Cost Sharing Cost sharing is a portion of the project

or program costs which are not borne by the awarding agency/sponsor

Although agencies/sponsors may define cost sharing, matching, and leveraging differently, at UW-Madison each requires the same level of documentation

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Cost Sharing continued

Required versus encouraged versus voluntary If required, only provide up to the

required level If encouraged, only include a

reasonable level Otherwise, do NOT include

All must be documentable

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When personnel effort = salary plus fringe benefits plus indirect costs (if indirect costs are allowed)

When cash – must be captured in a 133 account designated specifically as a “match” account; must be used during the same award period as the award it is being used to match

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When an award is made, cost sharing of personnel effort must be set up prior to an account number being established

http://www.rsp.wisc.edu/forms/costsharefrm.pdf Informational copies of completed forms

are sent to the Principal Investigator, Department/Center Administrator, and Individual(s) being cost shared

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When an award is made, cash match accounts must also be set up prior to an account number being established

Other forms of cost sharing – manner of tracking/reporting and who is responsible for such must be defined prior to an account number being established

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Criteria for Cost Sharing Must be verifiable from the

recipient’s accounting records May not be included as a contribution

for any other project or program Must be necessary and reasonable

for proper and efficient accomplishment of the project or program objectives

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Criteria for Cost Sharing continued

Must be allowable under applicable cost principles

Must be provided for in the approved project budget

Unrecovered indirect costs may be included with prior approval of the federal awarding agency

Federal support cannot be used toward another federal award

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Financial Issues Do not payroll individuals on awards

on which they are not associated/working Payrolling on a grant account as a

“holding place” until a new award or continuation funding is received is not allowable

Establish advance accounts or utilize unrestricted funding (i.e., 101s, 133 gifts, etc.)

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Financial Issues continued

Be aware of the terms and conditions that apply to each award

FDP (Federal Demonstration Partnership) streamlines the administrative process and minimizes the administrative burden while maintaining effective stewardship of federal funds

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Unallowable expenditures: Administrative & clerical salaries Local telephone service Office supplies Postage Dues & memberships Subscriptions, books, & periodicals General purpose equipment (i.e., computers, copy

machines, etc.) General computer services, networking costs, &

other DoIT services Staff recruitment & relocation

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Use of procurement cards – purchases must be allowable

Premium processing fees on visa applications are unallowable

Use of daily rate structures are unallowable

Special invoicing/reporting requirements flow down to the college and departments/centers

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Account Numbers in Advance Complete a “Request for Account

Number in Advance of Award” (form 88-1)

http://www.rsp.wisc.edu/forms/88-1.pdf Attach copies of approved protocols Attach documentation from the

funding agency/sponsor that award is forthcoming

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Account Number in Advance continued

Problem – departments are responsible for incurred costs when an award is not received

Problem – 90 day pre-spending is not allowable by all agencies/sponsors

Problem – some awards are effective upon date of last signature

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Subcontracts Subcontract costs represent a

collaboration of work by more than one institution

UW may be a subcontractor in another agency/institution’s proposal

Another agency/institution may be a subcontractor within a proposal/award to UW

Paperwork requires agency/institutional approvals prior to inclusion

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Subcontracts continued

http://www.cals.wisc.edu/research/infopolproc.html Issue on a yearly basis Prior to continuation, consult with PI to

confirm acceptable performance to date Final period of continuation should end 90

days prior to the official award end date Subs to UW departments are handled via

subaccount request form

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Cost transfers A cost transfer is a transfer of a

previously recorded expenditure from one funding source to another Salary payment transfers Non-salary payment transfers

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Cost Transfers continued

Why? Correction of data entry error Service center charges Reallocation of effort Continuation year of a project Pre-award costs

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When allowable? In accordance with the terms and

conditions of the award document Supported by acceptable

documentation justifying the transfer Certified as to the correctness of the

charge

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When unallowable? To meet deficiencies caused by overruns

or other financial considerations To avoid restrictions imposed by law or by

the terms of the sponsored agreement Due to funds terminating with

unexpended balances Clean up efforts at the end of an award For convenience After PAR certification has occurred

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What is required? Documentation! Justification! Clarity and detail!

Documentation must include a full explanation of how the situation occurred and actions being taken to alleviate future occurrences

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Timeliness Must submit as soon as issue is

discovered 90-days is the standard CALS strongly encourages actions

within 45 days Prior to PAR certification!

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Recommendations Review accounts monthly Do not use grants for “parking”

expenses Set up accounts in advance when

appropriate

Keep in mind – transfers are a “big red flag” to auditors

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Gifts-in-Kind Gifts-in-Kind (non-monetary gifts)

require formal acceptance by the Board of Regents

http://www.rsp.wisc.edu/html/giftinkind.html

Route transmittal form through department/center, college, and RSP for review and approval

Attach letter from donor

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Equipment Loans Risk Management has a property

program which manages equipment located at off-campus facilities or loaned to another institution

For information refer to their website: http://www.bussvc.wisc.edu/risk_mgt/property_program.html

For form to authorize equipment loans: http://www.bussvc.wisc.edu/acct/propcont/propform.html

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No Cost Extensions Extension on an award needs to be

requested and approved prior to the award end date

Requests need to route from PI through department/center, college, and RSP to the agency/sponsor

http://www.cals.wisc.edu/research/forms.html FDP awards – request must still be

routed; campus has authority to approve first extension

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Reporting, Modifications, etc. Communication – keep departments/

centers, college, and RSP in the loop Budget modifications Scope of work/project modifications Addition/deletion of subcontractors

or consultants Exceptions Reports Etc.

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RSP Update Director RSP – William Vance Assistant Director Pre-award – Diane Barrett Assistant Director Post-award – Bob Andresen Policy & Planning Analyst – Francine Massey Pre-award Team 2 – Stephanie Gray, Christy

Wipperfurth, and vacancy Post-award – Non federal accountant Jane

Braun; Federal accountants by agency; Team transition pending

Material transfer agreements – Mark Doremus

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PALS RSP’s Pre-Award Login System

Proposals are logged in when received at RSP Actions/status information is accessible viahttps://www.rsp.wisc.edu/services/admin/pals/c_slookup.cfm Query by PI Name, UDDS, Agency, etc. CALS will be a test site Departments will be involved through

transmittal entry which will capture data and allow for tracking from department/center issuance to college to RSP to agency/sponsor

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Helpful Websites CALS Research Division

http://www.cals.wisc.edu/research

Research & Sponsored Programs

http://www.rsp.wisc.edu

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Questions??? How can we help? What can we clarify? Need us to meet with

departments, centers, individuals?

Documents

1 Grants Management, Financial Responsibilities, and Research Related Issues Carol Hillmer Assistant Dean CALS Research Division November 19, 2003