UNIVERSITY OF MIAMI Compensation, E ffort Certification & Reporting & UNIVERSITY OF MIAMI Compensation, E ffort Certification & Reporting & OMB CIRCULAR

UNIVERSITY OF MIAMIUNIVERSITY OF MIAMI

CCompensation, ompensation,

EEffort Certification & Reporting ffort Certification & Reporting

&&

OMB CIRCULAR A-110

CompensationCompensation

Per OMB Circular A21 – for services Per OMB Circular A21 – for services performed under sponsored agreements:performed under sponsored agreements:

Compensation = salaries, wages & benefitsCompensation = salaries, wages & benefits

paidpaid by UM times % devoted to the project. by UM times % devoted to the project.

Compensation is allowable as direct costCompensation is allowable as direct cost on grants and contracts to the extent thaton grants and contracts to the extent that total compensation conforms total compensation conforms to theto the established policies of the institution, established policies of the institution, consistently applied.consistently applied.


CHARGES TO A SPONSORED AGREEMENT:CHARGES TO A SPONSORED AGREEMENT:

May include reasonable amounts for activities May include reasonable amounts for activities contributing & intimately relatedcontributing & intimately related to work under to work under the sponsored agreements. Examples: the sponsored agreements. Examples:

delivering special lectures about specific aspects of delivering special lectures about specific aspects of the ongoing activity, the ongoing activity,

consulting with colleagues and graduateconsulting with colleagues and graduate students,students, participating in appropriate seminars, participating in appropriate seminars, writing reports and articles, and writing reports and articles, and attending meetings and conferencesattending meetings and conferences. .

CompensationCompensationPer NIH, INSTITUTIONAL BASE SALARY (IBS)Per NIH, INSTITUTIONAL BASE SALARY (IBS)

Is the salary used in proposal preparation & in Is the salary used in proposal preparation & in charging sponsored accounts.charging sponsored accounts.

Defined as the annual compensation Defined as the annual compensation paidpaid for an for an employee's appointment, whether that time isemployee's appointment, whether that time is spent on research, teaching, patient care, or otherspent on research, teaching, patient care, or other activities. activities.

ExcludesExcludes outside income: permitted external outside income: permitted external consulting; VA, etc.consulting; VA, etc.

May May notnot be increased as a result of replacing be increased as a result of replacing organizational salary funds with NIH grant funds. organizational salary funds with NIH grant funds.


Distribution of salaries & wages to sponsored Distribution of salaries & wages to sponsored projects OR other activities (teaching, patient projects OR other activities (teaching, patient care, administration) , must be based on care, administration) , must be based on payrolls that are payrolls that are documenteddocumented…(…(documentation documentation will be discussed later under effort reporting)will be discussed later under effort reporting)

If chargeable to more than one sponsored If chargeable to more than one sponsored agreement -agreement - Conform to OMB Circular A21 Sections A2 & C:Conform to OMB Circular A21 Sections A2 & C:

A2 = Employ sound management practicesA2 = Employ sound management practices C = Costs must be Allowable: C = Costs must be Allowable:

Reasonable, Allocable (direct benefit to the project), Reasonable, Allocable (direct benefit to the project), consistently appliedconsistently applied

EFFORT EFFORT CERTIFICATION & CERTIFICATION &

REPORTINGREPORTING

Let’s set the stageLet’s set the stage

Federal Government probes have resulted in:Federal Government probes have resulted in: Florida International University (FIU)Florida International University (FIU)

Paid $11 million in audit disallowances – probe not Paid $11 million in audit disallowances – probe not yet completed.yet completed.

Northwestern University Northwestern University Audit disallowances of $5.5 M Audit disallowances of $5.5 M

University of South FloridaUniversity of South Florida Returned $ 4.1 M to the federal government Returned $ 4.1 M to the federal government

Other recent cases involve:Other recent cases involve: Harvard $3.3 M, Johns Hopkins $2.6 M, U AlabamaHarvard $3.3 M, Johns Hopkins $2.6 M, U Alabama $3 M, U of California $2.1, U Connecticut $2 M$3 M, U of California $2.1, U Connecticut $2 M

EFFORT REPORTINGEFFORT REPORTING

EFFORT REPORTINGEFFORT REPORTING

NIH – Office of Inspector General (OIG) 2006 Audit PlanNIH – Office of Inspector General (OIG) 2006 Audit Plan - - will determine whether NIH grant effort promised in proposals are will determine whether NIH grant effort promised in proposals are inflated as NIH funds intended to pay for salary could possibly be used inflated as NIH funds intended to pay for salary could possibly be used for costs not included in the proposal, affecting the research quality.for costs not included in the proposal, affecting the research quality.

The National Science Fdn - Office of Inspector General -The National Science Fdn - Office of Inspector General - 2006 Audit Plan: 2006 Audit Plan: effort reporting will be carefully reviewed at effort reporting will be carefully reviewed at

grantee institutionsgrantee institutions..

Congress - In September, asked the HHS-OIG Congress - In September, asked the HHS-OIG to carefully to carefully audit research grantees for false statements, improper accounting, audit research grantees for false statements, improper accounting, improper charges and double billing.improper charges and double billing.

Conclusion the enforcement landscape has changed & the Conclusion the enforcement landscape has changed & the stakes are substantial.stakes are substantial.

• the financial stakes are substantial.

EFFORT EFFORT

EFFORT IS DEFINED AS:EFFORT IS DEFINED AS:

• Total employee’s time spent onTotal employee’s time spent on University activities for which the University activities for which the employee is compensatedemployee is compensated

++ ++ ++

Combination of the above = 100%Combination of the above = 100%

EFFORT CERTIFICATION & REPORTING - WHY DO IT?EFFORT CERTIFICATION & REPORTING - WHY DO IT?

Section J10 of OMB Circular A-21 requires it:Section J10 of OMB Circular A-21 requires it:

Salaries and wages charged to sponsored Salaries and wages charged to sponsored agreements are allowable agreements are allowable onlyonly if they are if they are supported/documented by an Effort Reporting supported/documented by an Effort Reporting SystemSystem

Principal Investigators and the University are Principal Investigators and the University are ultimately responsible for ensuring that all charges toultimately responsible for ensuring that all charges to an award are appropriate, an award are appropriate, including salary chargesincluding salary charges

EFFORT CERTIFICATION & EFFORT CERTIFICATION & REPORTINGREPORTING

EFFORT CERTIFICATION & REPORTINGEFFORT CERTIFICATION & REPORTING

Per OMB Circular A-21:Per OMB Circular A-21:

The method for documenting effort must:The method for documenting effort must:

ReasonablyReasonably reflect reflect allall of the activities performed of the activities performed by the employee for which he/she is by the employee for which he/she is paidpaid by UM by UM

Include Include after-the-factafter-the-fact confirmation to ensure that confirmation to ensure that initial salary charges reasonably approximateinitial salary charges reasonably approximate actual effortactual effort

After the fact confirmation requires that an effort After the fact confirmation requires that an effort report be report be signed (certified).signed (certified).

At UM faculty must certify their own effort. At UM faculty must certify their own effort. Other staff - either the staff member or theOther staff - either the staff member or the person with first hand knowledge of how the person with first hand knowledge of how the effort was spent must certify.effort was spent must certify.

EFFORT CERTIFICATION & REPORTINGEFFORT CERTIFICATION & REPORTING

University compensated effort University compensated effort includesincludes all research, all research, teaching, administration, clinical activity, and any otherteaching, administration, clinical activity, and any other

activity for which an individual receives compensationactivity for which an individual receives compensation from the University (it does not include clinical bonus).from the University (it does not include clinical bonus).

ExcludedExcluded from effort reporting is any compensation from effort reporting is any compensation received from sources other than the University, suchreceived from sources other than the University, such as compensation from the VA, or outside consultingas compensation from the VA, or outside consulting work permitted by the University.work permitted by the University.

Effort distributions should be Effort distributions should be REASONABLE ESTIMATES REASONABLE ESTIMATES of activities, recognizing that research, instruction, & of activities, recognizing that research, instruction, & clinical activity are often inextricably intermingled.clinical activity are often inextricably intermingled.

Sponsored Projects ActivitiesSponsored Projects Activities::

effort devoted to grants, contracts, & effort devoted to grants, contracts, & cooperative agreements sponsoredcooperative agreements sponsored by external entities, by external entities, i.e., federal, state, locali.e., federal, state, local

governments, foundations, corporations, etc.,governments, foundations, corporations, etc., for purposes for purposes of research, research training, & clinical trials.of research, research training, & clinical trials.

Instruction & Departmental researchInstruction & Departmental research::

effort devoted to teaching and training activities effort devoted to teaching and training activities where the employee is the instructor. where the employee is the instructor. Includes Includes classroom and course preparation, grading classroom and course preparation, grading

exams, & academic advising of students.exams, & academic advising of students. Departmental research includes research notDepartmental research includes research not sponsored by an external organization & notsponsored by an external organization & not separately budgeted & accounted for.separately budgeted & accounted for.

Activities Included in Effort ReportsActivities Included in Effort Reports


Clinical ActivitiesClinical Activities:: effort devoted toeffort devoted to

• the direct treatment of clinical the direct treatment of clinical patients for which a patients for which a professional bill would ordinarily be rendered;professional bill would ordinarily be rendered;

• teaching and/or supervising clinical personnel, teaching and/or supervising clinical personnel, residents, interns. Includes preparation of lectures residents, interns. Includes preparation of lectures which does not properly belong under the which does not properly belong under the Instructional Activity in the prior slide; andInstructional Activity in the prior slide; and

• the administration of ancillary or inpatient the administration of ancillary or inpatient areas, areas, including budget management, and supervision of including budget management, and supervision of technical and clerical personnel, related committees, technical and clerical personnel, related committees,

in-service education programs, and activity of in-service education programs, and activity of general benefit to clinical patient care, i.e., patient general benefit to clinical patient care, i.e., patient safetysafety

AdministrationAdministration: effort devoted to departmental : effort devoted to departmental business activities, proposal & bid preparation, business activities, proposal & bid preparation, sponsored projects administration, serving on sponsored projects administration, serving on human, animal subjects, or other committees, human, animal subjects, or other committees, and and supervising administrative staff.supervising administrative staff.

• Other ActivitiesOther Activities:: Service Centers – internal UM services whose Service Centers – internal UM services whose goal is to operate on a break even basis.goal is to operate on a break even basis. Student Services – enrollment, admissions,Student Services – enrollment, admissions, registrar, financial registrar, financial aidaid Institutional Support – central administration, i.e.,Institutional Support – central administration, i.e., Purchasing, Purchasing, Payroll, General Counsel, etc.Payroll, General Counsel, etc.


Effort Certification & ReportingEffort Certification & Reporting

Effort and payroll distributions are not the same thing.Effort and payroll distributions are not the same thing.

Effort certification &Effort certification & reportingreporting

is a method for documenting is a method for documenting salary charges made to salary charges made to sponsored awards as sponsored awards as required by the government required by the government (OMB Circular A-21)(OMB Circular A-21)

Payroll distributionPayroll distributionis the actual charge is the actual charge recorded in Labor History recorded in Labor History originating from a Personnel originating from a Personnel Event Form (PEF) or DHRS Event Form (PEF) or DHRS online transaction. Used online transaction. Used initially as a proxy for effort initially as a proxy for effort distribution.distribution.

Therefore, since effort reports are based initially on the payroll Therefore, since effort reports are based initially on the payroll distribution + or – any adjusting entries processed:distribution + or – any adjusting entries processed:

RRetroactive effort changes require a change to the payroll chargesetroactive effort changes require a change to the payroll charges recorded in a sponsored account. Submit an FEI or FA10 – berecorded in a sponsored account. Submit an FEI or FA10 – be aware of 90 day limitation aware of 90 day limitation

If effort changes are ongoing, a PEF/DHRS online transaction mustIf effort changes are ongoing, a PEF/DHRS online transaction must be submitted as well.be submitted as well.

Effort ReportingEffort ReportingThe effort process begins well before the effort report is The effort process begins well before the effort report is

generated.generated.

Pre-AwardPre-AwardPre-AwardPre-Award

Appointing Appointing Faculty & StaffFaculty & Staff

Preparing the Preparing the Proposal Proposal BudgetBudget

Charging SalaryCharging Salary

Post-AwardPost-AwardPost-AwardPost-Award

Employment terms Employment terms are established are established

including including # months (contract # months (contract

period), period), % full time, % full time, salary basesalary base

Effort is Effort is proposed, & a proposed, & a commitment is commitment is

made to the made to the sponsorsponsor

Salary isSalary is charged at the charged at the

same time same time activity occurs.activity occurs.

Effort is Effort is certified after certified after

activity has activity has occurredoccurred

Relating pay Relating pay to the effortto the effort

If different from salary charged, a

journal entry correcting the

charge is initiated

If different from salary charged, a

journal entry correcting the

charge is initiated

AwardAward ReceivedReceived

Effort - Cost SharedEffort - Cost Shared Effort performed on sponsored programs Effort performed on sponsored programs

may require cost sharing may require cost sharing

Cost sharing is the portion of a sponsored Cost sharing is the portion of a sponsored project or program costs not borne by the project or program costs not borne by the agencyagency

Salary cost sharing can be:Salary cost sharing can be:

MandatoryMandatory

Voluntary committedVoluntary committed

Voluntary uncommittedVoluntary uncommitted

OMB Circular A21 Clarification - Memo dated OMB Circular A21 Clarification - Memo dated 1/01 salary cost sharing can be:1/01 salary cost sharing can be: Mandatory *Mandatory *

Required by regulation (NIH salary cap), or by the grant RFA, Required by regulation (NIH salary cap), or by the grant RFA, stipulated in the award termsstipulated in the award terms

Voluntary Committed *Voluntary Committed * cost sharing specifically pledged in the proposal’s budget cost sharing specifically pledged in the proposal’s budget

(and by default in the award) (and by default in the award)

Voluntary UncommittedVoluntary Uncommitted faculty effort over and above that which is committed andfaculty effort over and above that which is committed and

budgeted for in a sponsored agreement budgeted for in a sponsored agreement * Must be d* Must be documented and captured as part of the awardocumented and captured as part of the award

Effort – Cost Shared Effort – Cost Shared

Effort – Cost SharedEffort – Cost Shared

Committed Cost Sharing:Committed Cost Sharing: Whether mandatory or voluntary, commitments Whether mandatory or voluntary, commitments

are a condition of an award, & must be captured are a condition of an award, & must be captured in the accounting systemin the accounting system A companion sponsored account is set up to record A companion sponsored account is set up to record

UM funded costsUM funded costs

Cost sharing expenses must be reported to the agencyCost sharing expenses must be reported to the agency

Must be properly documented for cost accounting Must be properly documented for cost accounting purposes (i.e. F&A rate calculation) – purposes (i.e. F&A rate calculation) – cost sharing cost sharing reduces the F&A ratereduces the F&A rate

Committed faculty effort must be captured in payroll Committed faculty effort must be captured in payroll distribution systemdistribution system

Since Voluntary Uncommitted or Since Voluntary Uncommitted or faculty-donated effort is not subject to faculty-donated effort is not subject to the requirements of Circular A-21, there the requirements of Circular A-21, there is no need to document uncommitted is no need to document uncommitted cost sharing for cost accounting cost sharing for cost accounting purposespurposes

Therefore, Voluntary Uncommitted Therefore, Voluntary Uncommitted faculty effort is excluded from effort faculty effort is excluded from effort reporting requirementreporting requirement

Effort – Cost SharedEffort – Cost Shared

Cost Sharing Example – NIH SALARY CAPCost Sharing Example – NIH SALARY CAP

Salary $200,000 annuallySalary $200,000 annually Current NIH Salary Cap $183,500 *Current NIH Salary Cap $183,500 *

Committed Annual Monthly % forCommitted Annual Monthly % for AnnualAnnual EffortEffort Grant SalGrant Sal Divide by 12Divide by 12 PayrollPayroll

Institutional Base Sal $200,000 X 20% = $40,000 $3,333.33 Institutional Base Sal $200,000 X 20% = $40,000 $3,333.33

Capped at * $183,500 X 20% = Capped at * $183,500 X 20% = $36,700$36,700 $3,058.33$3,058.33 18.35%18.35% ** **

Cost shared by UMCost shared by UM $7,500 X 20% = $7,500 X 20% = $3,300$3,300 $275.00$275.00 1.65%1.65%

* Salary cap changes annually & applies to* Salary cap changes annually & applies to NIH (27 institutes & centers), the Agency forNIH (27 institutes & centers), the Agency for Healthcare Research and Quality (AHRQ), and the Substance Abuse and Mental HealthHealthcare Research and Quality (AHRQ), and the Substance Abuse and Mental Health Services AdministrationServices Administration (SAMHSA) (SAMHSA)

** Payroll % arrived at by dividing 36,700 (annual grant salary paid by NIH) by the annual ** Payroll % arrived at by dividing 36,700 (annual grant salary paid by NIH) by the annual Institutional Base Salary (IBS) of $200,000 = 18.35%; ORInstitutional Base Salary (IBS) of $200,000 = 18.35%; OR divide IBS $200,000 by 12 = 16,666.67 and then divide monthly capped salary $3,058.33divide IBS $200,000 by 12 = 16,666.67 and then divide monthly capped salary $3,058.33 by $16,666.67 = 18.35%by $16,666.67 = 18.35%

Total committed effort = 20%Total committed effort = 20%

Actual effort expended = 25%Actual effort expended = 25%

Cost Sharing Example – NIH Salary CapCost Sharing Example – NIH Salary Cap

What should be set up in Payroll for this NIH award?What should be set up in Payroll for this NIH award? 18.35% or $3,058.33 monthly salary charged to the NIH18.35% or $3,058.33 monthly salary charged to the NIH

Award Award ANDAND 1.65% or $275.00 monthly salary charged to the Sponsored1.65% or $275.00 monthly salary charged to the Sponsored

Companion Cost Sharing Acct.Companion Cost Sharing Acct.

What will the effort report distribution show?What will the effort report distribution show? Same as above… However, new system will also show the total Same as above… However, new system will also show the total

effort for the award, in this case 20%effort for the award, in this case 20%

What happens with effort above Committed Effort?What happens with effort above Committed Effort? The difference between Actual Effort Expended and Total The difference between Actual Effort Expended and Total

Committed Effort is voluntary uncommitted effort. Therefore, Committed Effort is voluntary uncommitted effort. Therefore, the total effort the total effort reportedreported is 20% is 20%

EffortEffort NIH Career Awards – (NIH Career Awards – (K awardsK awards):):

Most career awards require a Most career awards require a minimumminimum commitment of commitment of total professional effort to researchtotal professional effort to research

Types: Independent, Mid Career, Senior Career Awards; Mentored Types: Independent, Mid Career, Senior Career Awards; Mentored Career Development, etc.Career Development, etc.

To meet required commitment of effort:To meet required commitment of effort:

Individual must have a full-time appointment at UMIndividual must have a full-time appointment at UM

MinimumMinimum % of individual’s commitment proposed must % of individual’s commitment proposed must be covered by the UM appointmentbe covered by the UM appointment

For specific required minimum % of effortFor specific required minimum % of effort Review K award term and conditionsReview K award term and conditions View the requirements for each type of K award at:View the requirements for each type of K award at:

http://grants2.nih.gov/training/careerdevelopmentawards.htmhttp://grants2.nih.gov/training/careerdevelopmentawards.htm

Effort ReportingEffort Reporting

Paper based system at UMPaper based system at UM In process of changingIn process of changing to Web systemto Web system Testing now being doneTesting now being done Training Training

Administrators Administrators Late June/early JulyLate June/early July

Faculty & other certifiersFaculty & other certifiers September (9 months faculty)September (9 months faculty) November (12 month faculty)November (12 month faculty)

Effort ReportingEffort ReportingPer NIH - Top 10 Issues on salary charges Per NIH - Top 10 Issues on salary charges

1.1. Certifying official does not have first-hand Certifying official does not have first-hand knowledge of effort performedknowledge of effort performed

2.2. Effort reports not certified and returned in a Effort reports not certified and returned in a timely mannertimely manner

3.3. Certifying the budgeted effortCertifying the budgeted effort

4.4. Salary cap not treated correctly with respect Salary cap not treated correctly with respect to effort and charging NIH grants/contractsto effort and charging NIH grants/contracts

5.5. Corrections for significant changes in effort Corrections for significant changes in effort are not made OR not made in a timely mannerare not made OR not made in a timely manner

Effort ReportingEffort ReportingPer NIH - Top 10 Issues, continuedPer NIH - Top 10 Issues, continued

6.6. Transferring costs from one project to another Transferring costs from one project to another to avoid a cost overrunto avoid a cost overrun

7.7. Failure to get prior approval for change in key Failure to get prior approval for change in key personnel, i.e., withdraw from project personnel, i.e., withdraw from project completely, be absent for 3 months or more or completely, be absent for 3 months or more or reduces time by 25% or morereduces time by 25% or more

8.8. Overlap of support (scientific or budgetary)Overlap of support (scientific or budgetary)

9.9. Overlap of commitmentOverlap of commitment

10.10. Use of incorrect IBS (institutional base salary), Use of incorrect IBS (institutional base salary), especially when clinical practice especially when clinical practice compensation is involvedcompensation is involved

Effort ReportingEffort Reporting

Per NIH – What is at Risk for Non Per NIH – What is at Risk for Non Compliance?Compliance?

o Audit Findings/Cost DisallowancesAudit Findings/Cost Disallowanceso Designation as High Risk OrganizationDesignation as High Risk Organizationo Special Terms and Conditions on NGAsSpecial Terms and Conditions on NGAso Requirement for Corrective Action PlanRequirement for Corrective Action Plano Special Monitoring by NIHSpecial Monitoring by NIHo Temporary Withholding of PaymentsTemporary Withholding of Paymentso Withholding of Future AwardsWithholding of Future Awards

QUESTIONS ON QUESTIONS ON

COMPENSATION COMPENSATION

OR OR

EFFORT BEFORE EFFORT BEFORE

CONTINUING?CONTINUING?

(OMB) CIRCULAR A-110(OMB) CIRCULAR A-110

Administrative Requirements Administrative Requirements for Grants and Agreements for Grants and Agreements

With Institutions of Higher EducationWith Institutions of Higher Educationhttp://www.whitehouse.gov/omb/circulars/a110/a110.htmlhttp://www.whitehouse.gov/omb/circulars/a110/a110.html

OMB Circular A110OMB Circular A110

Sets the standards Sets the standards

For how universities do business with For how universities do business with federal awarding agencies,federal awarding agencies,

For the financial systems that For the financial systems that universities must put into place, and universities must put into place, and

For how universities must administer For how universities must administer federal awards. federal awards.


Included in A110 are regulations for:Included in A110 are regulations for:A.A. Financial management systemsFinancial management systemsB.B. Cost SharingCost SharingC.C. Grant Related IncomeGrant Related IncomeD.D. Revision of budget or program plansRevision of budget or program plansE.E. PropertyPropertyF.F. ProcurementProcurementG.G. ReportingReportingH.H. RecordkeepingRecordkeepingI.I. CloseoutCloseout


A. Financial standardsA. Financial standards – MUST HAVES – MUST HAVES Accurate, current & complete disclosure of the Accurate, current & complete disclosure of the

financial results of each federally-sponsored project financial results of each federally-sponsored project

Records that identify adequately the source & Records that identify adequately the source & application of funds for federally-sponsored application of funds for federally-sponsored activitiesactivities

Comparison of expenses with budget amounts for Comparison of expenses with budget amounts for each award. each award.

Written procedures for determining the Written procedures for determining the reasonableness, allocability and allowability of costs reasonableness, allocability and allowability of costs (per OMB Circular A21 & the terms & conditions of (per OMB Circular A21 & the terms & conditions of the award).the award).

B. Cost SharingB. Cost Sharing

Cost sharing or matching is the portion of a Cost sharing or matching is the portion of a sponsored project or program costs not sponsored project or program costs not borne by the agency.borne by the agency.

UMUM AgencyAgency TotalTotal

$$ + + $ = $ = AwardAward


COST SHARING must follow the following criteria:COST SHARING must follow the following criteria:

Be verifiable from UM’s accounting recordsBe verifiable from UM’s accounting records

Not used as cost sharing for any other sponsoredNot used as cost sharing for any other sponsored programprogram Allowable (reasonable, necessary to the performanceAllowable (reasonable, necessary to the performance project objectives, consistently applied)project objectives, consistently applied)

Not paid by Federal government under another awardNot paid by Federal government under another award Incurred during the effective dates of grantIncurred during the effective dates of grant Reflected in the proposal budget when required byReflected in the proposal budget when required by

the agencythe agency


Cost share can be satisfied via:Cost share can be satisfied via: Cash:Cash:

Outgoing - payment of expenses (i.e., salaries, Outgoing - payment of expenses (i.e., salaries, supplies, equipment, etc.)supplies, equipment, etc.)

Incoming - contributions received for the projectIncoming - contributions received for the project

In-Kind: In-Kind: VValue of non-cash contributions provided by non-alue of non-cash contributions provided by non-

Federal third parties. Examples of non-cash Federal third parties. Examples of non-cash contributions: services, supplies, equipment (donated contributions: services, supplies, equipment (donated and used for the project).and used for the project).

Must be documented, in writing, by using the fair Must be documented, in writing, by using the fair market value of the non-cash item at time of donation.market value of the non-cash item at time of donation.


Unrecovered F&A may be included as part of Unrecovered F&A may be included as part of cost sharing or matching cost sharing or matching onlyonly with the prior with the prior approval of the Federal awarding agency. approval of the Federal awarding agency.

Example:Example: Agency only allows 15% of F&AAgency only allows 15% of F&A Agency requires cost sharingAgency requires cost sharing Difference between approved UM rate and 15% can Difference between approved UM rate and 15% can

be used as cost sharing if federal agency be used as cost sharing if federal agency approves.approves.



C. GRANT RELATED / PROGRAM INCOMEC. GRANT RELATED / PROGRAM INCOME

Earned by a granteeEarned by a grantee - directly generated by the grantdirectly generated by the grant supported activity or earned as a result of the award supported activity or earned as a result of the award

Includes, but is not limited to, INCOME RECEIVED FROM:Includes, but is not limited to, INCOME RECEIVED FROM: fees for services performed; such as lab tests,fees for services performed; such as lab tests,

the use, rental or sale of equipment or supplies acquiredthe use, rental or sale of equipment or supplies acquired or fabricated under the grant;or fabricated under the grant;

fees from participants at conferences or symposiafees from participants at conferences or symposia

sale of research material such as animal models orsale of research material such as animal models or reagentsreagents sale of software, tapes or publicationssale of software, tapes or publications


Grant Related Income - Accounting TreatmentGrant Related Income - Accounting Treatment

Grant Related Income is retained by UM & must be Grant Related Income is retained by UM & must be used in one of 3 ways:used in one of 3 ways:

Added to funds committed to the project …. & usedAdded to funds committed to the project …. & used

to further the project objectivesto further the project objectives

Deducted from the total project allowable cost inDeducted from the total project allowable cost in

determining the net allowable costs on whichdetermining the net allowable costs on which

the Federal share of costs is based the Federal share of costs is based Combination of addition and deductionCombination of addition and deduction

Amount of program income & amount expended must Amount of program income & amount expended must be reported to the agency - therefore, we must track be reported to the agency - therefore, we must track program income program income

OMB Circular A110OMB Circular A110Grant Related Income - Accounting TreatmentGrant Related Income - Accounting Treatment

Example: Example: A sponsor awards $100,000 for a project. The project generates income of $30,000.

AdditionAdditionTotal project cost should amount to $130,000. The additional funds should be kept in a companion sponsored account & requires reporting to the sponsor.

DeductionDeductionThe sponsor only funds $70,000 of the project's costs. The sponsor will deduct the amount of program

income from the total amount reimbursed.

CCombination: ombination:

Add/deductAdd/deduct

If the sponsor limit is $25,000, then $25,000 can

be added to the total project cost (companion account), and $5,000 will be deducted from the sponsor's payment to reduce it to $95,000. The total amount available is $125,000.


D. Revision of budget or program plansD. Revision of budget or program plans

PRIOR AGENCY APPROVALS – REQUIRED WHEN:PRIOR AGENCY APPROVALS – REQUIRED WHEN:

There is a change in:There is a change in:

the scope or the objective of the projectthe scope or the objective of the project

a key person specified in the application ora key person specified in the application or

award documentaward document

The PIThe PI is absent for more than 3 months is absent for more than 3 months

The PI reduces his/her time devoted to theThe PI reduces his/her time devoted to the project by 25 % or moreproject by 25 % or more


Allows grantee:Allows grantee: To incur pre-award costs 90 calendar days prior To incur pre-award costs 90 calendar days prior

to award or more than 90 calendar days with the to award or more than 90 calendar days with the prior approval of the Federal awarding agency.prior approval of the Federal awarding agency.

Initiate a one-time extension of the expiration date Initiate a one-time extension of the expiration date of the award of up to 12 months. Agency must be of the award of up to 12 months. Agency must be notified 10 days before expiration date.notified 10 days before expiration date.

Carry forward unobligated balances to Carry forward unobligated balances to subsequent funding periods – unless restricted subsequent funding periods – unless restricted by the terms of the award. by the terms of the award.


E. Property StandardsE. Property Standards – Moveable Equipment – Moveable Equipment

Provides guidelines for the management and disposition Provides guidelines for the management and disposition of property charged to a federal award:of property charged to a federal award:

Title to the property is usually kept by UM Title to the property is usually kept by UM Use object code 6103Use object code 6103

When title does not remain with UM per award terms When title does not remain with UM per award terms Use object code 6810 Use object code 6810 Reports required to be sent to the federal agencyReports required to be sent to the federal agency

Use the equipment for the project, share it with other Use the equipment for the project, share it with other PIs performing federal research, PIs performing federal research,

Keep an inventory with detail information Keep an inventory with detail information At UM inventory is maintained by Property Accounting, At UM inventory is maintained by Property Accounting, If title remains with the government, identify it.If title remains with the government, identify it.

Loss, damage, theft? Must be investigated & Loss, damage, theft? Must be investigated & documenteddocumented

Property Standards - Intangible PropertyProperty Standards - Intangible Property

The Federal Government has the right to: The Federal Government has the right to: a royalty-free, nonexclusive & irrevocable a royalty-free, nonexclusive & irrevocable

right to reproduce, publish, or otherwise use right to reproduce, publish, or otherwise use the work for Federal purposes, and to the work for Federal purposes, and to authorize others to do so.authorize others to do so.

the research data so that they can be made the research data so that they can be made available to the public through the available to the public through the procedures established under the FOIA procedures established under the FOIA (Freedom of Information Act)(Freedom of Information Act)


F. Procurement StandardsF. Procurement Standards For the purchase of supplies and other For the purchase of supplies and other

expendable property, equipment, real expendable property, equipment, real property and other services with Federal property and other services with Federal funds funds

Codes of conductCodes of conduct maintain written standards of conduct.maintain written standards of conduct. provide for disciplinary actions. provide for disciplinary actions. No employee, officer, or agent shall participate in No employee, officer, or agent shall participate in

the selection, award, or administration of a the selection, award, or administration of a contract supported by Federal funds if a real or contract supported by Federal funds if a real or apparent conflict of interest would be involvedapparent conflict of interest would be involved

https://www.miami.edu/policies_procedures/Purchasing/PDF-https://www.miami.edu/policies_procedures/Purchasing/PDF-Version/BSJ-025.pdfVersion/BSJ-025.pdf


Procurement StandardsProcurement Standards CompetitionCompetition

https://www.miami.edu/policies_procedures/Purchasing/PDF-https://www.miami.edu/policies_procedures/Purchasing/PDF-Version/BSJ-015.pdfVersion/BSJ-015.pdf

To the maximum extent practical, be conducted in To the maximum extent practical, be conducted in open and free competition. open and free competition.

ProceduresProcedures Avoid purchasing unnecessary items. Avoid purchasing unnecessary items. Utilize small business & minority firms whenever Utilize small business & minority firms whenever

possiblepossible Justification for lack of competition when Justification for lack of competition when

competitive bids or offers are not obtainedcompetitive bids or offers are not obtained Basis for cost or price of items purchased. Basis for cost or price of items purchased.


Procurement StandardsProcurement Standards Contract provisions must provide forContract provisions must provide for

Contractual or legal remedies in instancesContractual or legal remedies in instances

of contract violations. Also provide for remedial of contract violations. Also provide for remedial actionsactions

Provisions for termination by both partiesProvisions for termination by both parties Access to records of contractor by Federal Access to records of contractor by Federal

awarding agency, the Comptroller General of the awarding agency, the Comptroller General of the United States, or any of their duly authorized United States, or any of their duly authorized representatives representatives

Inclusion of terms stipulated in Attachment A of Inclusion of terms stipulated in Attachment A of A-110 (see last page of handout)A-110 (see last page of handout)


G. ReportingG. Reporting Federal agencies prescribe timing of Federal agencies prescribe timing of performance & financial reportsperformance & financial reports Final reports are due 90 calendar days after the end of the Final reports are due 90 calendar days after the end of the

award for:award for: Performance Performance

Issued by the Principal InvestigatorIssued by the Principal Investigator Financial StatusFinancial Status

Issued by Sponsored Programs – Post Award OfficeIssued by Sponsored Programs – Post Award Office InventionsInventions

Issued by the Principal InvestigatorIssued by the Principal Investigator Property Property

When required (government title) issued by Property When required (government title) issued by Property Accounting`Accounting`


H. RecordkeepingH. Recordkeeping

Financial records, supporting documents, statistical Financial records, supporting documents, statistical records, and all other records pertinent to an award records, and all other records pertinent to an award shall be retained for a period of shall be retained for a period of three yearsthree years from the from the

date of submission of the final expenditure reportdate of submission of the final expenditure report

If any litigation, claim, or audit is started before the If any litigation, claim, or audit is started before the expiration of the 3-year period, the records shall be expiration of the 3-year period, the records shall be retained until all litigation, claims or audit findings retained until all litigation, claims or audit findings involving the records have been resolved and final involving the records have been resolved and final action taken. action taken.


I. CloseoutI. Closeout

Complete all required reports withinComplete all required reports within

the 90 day the period the 90 day the period

If performance has not been completed request an If performance has not been completed request an extension to complete BEFORE the end of the grantextension to complete BEFORE the end of the grant Extensions are not granted because funds are left on the Extensions are not granted because funds are left on the

awardaward

Liquidate all obligations incurred under the award Liquidate all obligations incurred under the award not later than 90 calendar days after the date of not later than 90 calendar days after the date of completioncompletion


THANK YOUTHANK YOU

Documents

UNIVERSITY OF MIAMI Compensation, E ffort Certification & Reporting & UNIVERSITY OF MIAMI Compensation, E ffort Certification & Reporting & OMB CIRCULAR