GRANTS: CRADLE TO GRAVE

ALUMNI CENTERBALLROOMMAY 6, 2014

Post Award Processes&

Effort Reporting

Roberta McManusAssociate Director – Sponsored Research Administration

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Agenda

• Post Award Activities• Principal Investigator's (PI) Responsibilities• Compliance Regulations• Key Financial SR Policies• Budget & Expenditure Monitoring• SRAS Review of Expenditures• Collaboration with Other Researchers• OMNI Overview• PI Resources

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Post Award Activities• Award documents have been executed

Signed by appropriate institution authority

• Award is to FSU, not the PI• Proposal and Award number• Project number assigned – budget activated!

Cost sharing accounting• Research can begin

Adhere to scope of workCollaboration/subcontracting to other individuals/institutions

• Monitoring of activities - documentationStatus reportsTechnical reports

• Payments will be held if not submitted timely• Hold up future awards!!

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Post Award Activities Spending occurs

Plan ahead to meet deadlines Personnel – Human Resources policies and procedures Non Personnel – Purchasing/Travel/Subcontract/Non PO

policies and procedures Sponsored Research Accounting Coordinators review

allowability of most (not all) expenditures Billing/Collecting from agencies (SRA responsibility) Financial reporting to agencies (SRA responsibility) Amendments (SOW & Budgetary)

Contracting Officer for grantor and grantee Starts with Award Administrator

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Post Award Activities

• 90 days prior to award endNew funding increment?Request extension if needed/allowedNotify university grants officer in accordance with

timelines established

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Principal Investigator (PI) Responsibilities

• Understand agency rules/guidelines/restrictions• Conduct work timely/professionally• Comply with terms & conditions of award• Ensure expenditures benefit the project and are in

compliance with award• Monitor budget vs. expenditure over life of project• Ensuring commitments are met including cost share

requirementsObligations in proposal and/or award documents

• 2 months of PI’s effort for academic term• 15% of PI’s time for fall semester

Must be met whether paid from award or not

• Monitor subcontractor performance

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Award Closeout• SOW complete and final reports submitted• Expenditures are complete:

All charges incurred during project period are postedAvoid late cost transfers

Charges posted allowableNecessary and benefit the award

• Subcontractor SOW complete Final invoice processed timely

• Effort reported for amount of time expended on project• Commitments met

Funded or not funded by award

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Compliance Requirements

• FederalNew Federal guidance issued December 2013

Effective for awards/increments issues on/after December 26, 2014OMB Circulars applicable to University

• A-21 (more on this later!)• A-110 • A-133• Available on SR website at: http://

www.research.fsu.edu/sras/complianceresources.htmlAgency specific requirementsTerms and Conditions of award

• Non FederalTerms and Conditions rule!!

• FSU SR Related Policies and Procedureshttp://www.research.fsu.edu/contractsgrants/policypro.html#

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OMB Circular A-21

• SRS/SRAS use this resource daily

• Allowable means:Reasonable (prudent person)Allocable (relative benefits)Treatment is consistent (direct vs. indirect)Conforms to limitations or exclusions (e.g. salary caps)

• Direct costs“identified specifically with a particular sponsored project”

• Facilities & Administrative (F&A) costs“incurred for common or joint objectives and therefore

cannot be identified readily and specifically with a particular sponsored projects”

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OMB Circular A-21

• Cost Accounting Standards (CAS)

• Selected Cost Items (Section J)54 types of expenses and whether allowable vs. unallowable

• Any costs allocable to a particular sponsored

agreement may not be shifted to any other sponsored

agreements for the purpose of (Cost Transfer Policy)Convenience – includes charging a project while waiting for

another project/budget to be set up (Advance Policy)

Meeting deficiencies caused by overruns

Avoiding restrictions imposed by law or terms

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SR Financial Policies/Procedures

• Advances

• Cost Accounting Standards (CAS)

• Cost Sharing

• Cost Transfers

• Effort Commitments

• Fixed Price Residual Funds

• Indirect Cost Recovery

• Participant Support Costs

• Program Income

• Subrecipient Monitoring

• Unallowable Costs

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Advance Policy• Ensure timely start up or uninterrupted continuation effort

prior to having a fully executed award document

• Criteria

• Written/verbal assurance from sponsor

• Delays would adversely impact the program or increase costs

• Department assumes risk by financially backing the direct cost

amount to be advanced

• No work is to be initiated until authorized by SRA (as

evidenced by a project budget)

• DO NOT charge expenses for pending award to another

funding source

• Transfers will not be approved

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Cost Transfer Policy• Ensure that funds are properly managed• Indicators of inadequate fiscal monitoring

Frequent cost transfersLate cost transfersInadequately documented or justified cost transfers

• Examples of improper/unallowable cost transfersUtilizing unexpended fundsMoving overrun on one project to another projectMoving unallowable costs on one project to another projectCircumventing award restrictionsReimbursing a temporary “loan” of funds from another project

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Cost Transfer Policy• Proper cost transfers

The transfer represents an adjustment for an erroneous chargeSplit purchase

• Timeliness Essential to evidence sound fiscal managementMonthly reconciliations!!!!!

• PolicyPayroll/Non Payroll

• Within 90 days of end of the month in which error occurred OR• Within 30 days of the project expiration date

• Must complete Cost Transfer Justification Form• SRA Cost Transfer Committee

Assistant Director –SRA Accounting Chairs

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Cost Accounting Standards (CAS)

• FSU is required to disclose “costing practices” in a formalized document (Disclosure Statement-2)

• Describes how FSU treatsDirectF&A costs

• Facilities• Administration

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CAS – F&A Costs

• Examples of Costs that are normally treated as F&A:• Administrative and Clerical Salaries• Postage• Local Telephone• Office Supplies• Data Processing/Computer Supplies• General Purpose Software• Memberships• Subscriptions

• Cannot charge administrative and clerical expenses directly to a sponsored project unless there are exceptional circumstances

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CAS Exception Process• Must be documented for all federally-funded awards• Pertains to direct charge costs that are normally treated as

indirect costsPersonnelNon-personnel

• Inclusion in the budget in the award document does not automatically grant the exception

• Form at http://www.research.fsu.edu/contractsgrants/forms.html

• Justify exceptional circumstance• Submit to Sponsored Research Administration

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Cost Sharing

• Policy at http://www.research.fsu.edu/contractsgrants/costsharing.html

• Procedures at http://www.research.fsu.edu/contractsgrants/documents/csprocedures.pdf

• Definition = Costs not borne by FSU

• Criteria for tracking/reportingCommitted – Mandatory vs. Voluntary Committed

Must account for and report

“Project Enhancement” Do not have to account for and report

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Cost Sharing

• Include in the proposal budgetCost Share Commitment Form

Signed by Chair/Dean/Director

• Cost Share budgets are set up in OMNISponsored award/cost share budget set up same time

Important to get cost share info to SRA or will hold up being able

to spend

• Does not include 3rd party

• Transfer cash when using these funding sources:PI Support projects

SRAD projects

FSU Foundation

FSU Research Foundation

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Effort Certification• Effort = Amount of time expended on a particular activity• Federal government expects Universities to

Meet commitments of time by key personnel (PI/CO-PI) Provide evidence that commitments have been met

• Requires periodic reporting by faculty and other staff working on sponsored projects• Application = Faculty Assignments Effort Certification Tracking

(FACET) After each academic term (Fall, Spring, Summer) for Exempt (PIs) Monthly for Non-exempt employees (OPS – temporary) Provide reasonable estimates of time/effort spent on various

activities (instruction, advising, projects, etc.)

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Budget & Expenditure Monitoring

• Award is to the University…however

• PI responsible for ensuring expenditures benefit the projectTiming of when personnel need to be appointed

Timing of when supplies will be used

Collaboration with subcontractor in accordance with SOW

• Periodic budget vs. actuals reports (OMNI)Ensure anticipated expenditures charged

Review for expenditures that do not belong on project

Rate of expenditures reasonable for pace of research progress

Expect/Request expenditure reportsPersonnel – staff charged/encumbered

Non-personnel

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SRA Review of Expenditures

• Requisitions > $1,000• Travel and Expense reports > $1,000• Unencumbered expenses (pay requests/participant

requests) >$1,000• All personnel appointments

Payroll cost transfers (Retroactive Distribution of Funding – RDF) Cost Transfer Justification Form

• All journal entriesCost Transfer Justification Form

• All interdepartmental requisitionsSales between departments (stockrooms, machine time, etc.)

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SRA Review of Expenditures

• Compliance Evaluation Criteria Authorized Signature

• Sponsored Project Manager or PI

Chartfield Information• DeptID, Fund Code, Project Combination

Performance Period• Goods or Services received and consumed within

begin/end dates of award

• Available BalanceDirect cost budget check

• Budget category line item

• FDP/RTC

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SRA Review of Expenditures

• Account or Job CodeAppropriate for nature of expense

• AllowableRemember OMB Circular A-21!Terms and Conditions support expense

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Collaboration with Other Researcher

• Often included in proposalInstitution approval vs. researcher

• Participates in research (sub recipient) vs. provider of goods/services (vendor)

• Starts with SRA Subcontract Coordinator• Standard agreement

Incorporates Federal requirements

• Encumbered in OMNI as PO Numbers = RXXXX

• PI approves invoices (deliverables met)

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OMNI Overview

• Financial/Human Resource Systems• Project financial information

Job Aids on Division of Sponsored Research at http://www.research.fsu.edu/contractsgrants/• Available project balance inquiry• Generating project financial report• Running query of project expenditure detail• Generating HR report of payroll detail

Budget check against direct cost budgetExpenditures (costs incurred)Encumbrances (POs, T-Auths, personnel appointments)Not encumbered (future personnel appointments, tuition,

rent, F&A)

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PI Resources

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Training Opportunities

• CReATE – Compliance and Research Administration Training and EducationNext session Fall 2014New Federal guidance

• SRA Certificate SeriesCurriculum geared toward support staff Hands on toolsSummer schedule in processSchedule posted at

http://www.research.fsu.edu/contractsgrants/workshops.html

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Web Resources

• Office of Research

(http://www.research.fsu.edu/)• Division of Sponsored Research (

http://www.research.fsu.edu/contractsgrants/index.html)Staff Contact Information (SRAS assignments attached)Policies and ProceduresFormsFunding ResourcesOMNI InformationTraining InformationEmail/Newsletter Services (recommend getting on these list

serves)

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Web Resources• Controller’s Office (http://www.vpfa.fsu.edu/control/)

General AccountingPayroll ServicesProperty AccountingAccounts PayableTravel

• Office of Graduate Studies (http://gradstudies.fsu.edu/)Matriculation Waiver Information

• Purchasing (http://www.purchasing.fsu.edu/)

• Human Resources (http://hr.fsu.edu/)

• OMNI Resources (http://erp.fsu.edu/OMNI-Training)

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Contact Information

SRA Assignment Sheet http://www.research.fsu.edu/contractsgrants/documents/staff.pdf

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QUESTIONS