Post Award Basics
Rob Barbret, University of Michigan
Vivian Holmes, Broad Institute
Tracey Fraser, California Institute of
Technology
NCURA 51st Annual Meeting, October 2009
1
Overview of Workshop

The Rules

Establishing Accounts

Managing Spending on Awards

Overview of OMB Circular A-21

Cash Management
NCURA 51st Annual Meeting, October 2009
2
Overview of Workshop

Collections

Sub-recipient Monitoring

Cost Sharing

NIH Salary Cap
NCURA 51st Annual Meeting, October 2009
3
Overview of Workshop

Program Income

Effort Reporting

Close-out of Awards

Audits

Training
NCURA 51st Annual Meeting, October 2009
4
The Rules

OMB Circulars



A-21
Cost Principles for Educational
Institutions
A-110 Grants and Agreements with Institutions
of Higher Education: Uniform Admin
Requirements
A-133 Audits of Institution of Higher Education
and Other Nonprofit Institutions
http://www.whitehouse.gov/omb/circulars
NCURA 51st Annual Meeting, October 2009
5
The Rules

OMB Circulars



A-87
Cost Principles Applicable to Grants and
Contracts with State and Local
Governments
A-122 Cost Principles for Non-Profit
Organizations
Etc.
http://www.whitehouse.gov/omb/circulars
NCURA 51st Annual Meeting, October 2009
6
Order of Precedence
Award
Special Conditions
Program Rules
Agency Rules
OMB Circulars
NCURA 51st Annual Meeting, October 2009
7
Establishing New Accounts

Type of Awards
 Grant
 Cooperative Agreement
 Contract
 Gift
NCURA 51st Annual Meeting, October 2009
8
Establishing New Accounts

Grant

Principal purpose is to transfer money, property,
services or anything of value to recipient in order
to accomplish a public purpose

No substantial involvement is anticipated
between government and recipient during
performance of activity
NCURA 51st Annual Meeting, October 2009
9
Establishing New Accounts

Cooperative Agreement

Principal purpose is to transfer money, property,
services or anything of value to recipient in order
to accomplish a public purpose

Substantial involvement is anticipated between
government and recipient during performance of
activity
NCURA 51st Annual Meeting, October 2009
10
Establishing New Accounts

Contract

Principal purpose is to acquire property or services for
direct benefit or use of the federal government

Sponsor determines that procurement contract is
appropriate


Very restrictive, can have high demands
No expectation of cost sharing
NCURA 51st Annual Meeting, October 2009
11
Establishing New Accounts

Gift

A gift from a donor may carry a stipulation as to
its use, but there can be no expectation of
benefit back to the donor including the technical
and financial reports common to sponsored
project grants and contracts.
NCURA 51st Annual Meeting, October 2009
12
Establishing New Accounts
Grant





Contract
project conceived by
investigator
agency supports or
assists
performer defines
details and retains
scientific freedom
agency maintains
cognizance
unilateral





project conceived by
agency
agency procures service
agency exercises
direction or control
agency closely monitors
bilateral
NCURA 51st Annual Meeting, October 2009
13
Establishing New Accounts

Departments are often frustrated by the time
lag between receiving the award and
establishing the account.

Ideas to speed-up the process




Establish check-list for pre-award office
Determine what documents are “must haves” and what
can wait until after the account is established
Send data electronically or via fax whenever possible
Train departmental administrators
 Roles and responsibilities
 Required forms and documentation
NCURA 51st Annual Meeting, October 2009
14
Establishing New Accounts

Advance Account Numbers


Allow departments to formally request with signoff by Dean
Institution will be ultimately liable for expenses if
award is not granted



Individual institution culture will drive actual
funding
Pre-Award office authorizes the account based
on contact with sponsor
Eliminates the need for transfers after the
agreement is signed
NCURA 51st Annual Meeting, October 2009
15
Establishing New Accounts

Only establish a new account if the SPONSOR
requires it


New accounts are not necessary for each year of the
award
Spend time training the person establishing the
award in the accounting system

Understand data elements to ensure:



Billing vs. LOC is correct
F&A calculation will be accurate based on how the
account is established
Account Number Structure

Prime and Sub Account Relationships
NCURA 51st Annual Meeting, October 2009
16
Managing Spending on Awards

Reviewing expenditures

Establish reasonable practices for reviewing
expenditures


Does your university review all expenditures or
target higher risk transactions?
Rebudgeting
NCURA 51st Annual Meeting, October 2009
17
Managing Spending on Awards

Procurement Cards


Clearly define responsibilities:






Strong written policy needed
What is allowable?
Who maintains documentation?
Length of time records are to be kept
Beware of sponsored projects as default
Set dollar limits
Audit frequently
NCURA 51st Annual Meeting, October 2009
18
Managing Spending on Awards

Cost Transfers
 A cost transfer is an after-the-fact
transfer of expenditures from one project
to another project.
NCURA 51st Annual Meeting, October 2009
19
Managing Spending on Awards

Cost Transfers




“Transfer(s) must be justified by documentation that contains a
full explanation of how the error occurred...”
“An explanation that merely states ‘to correct error’ or ‘to
transfer to correct project’ is not sufficient.”
“It should be noted that frequent errors in the recording of costs
may indicate the need to review the accounting system and/or
internal controls.” (DHHS Grants Manual)
Part II of the NIH policy statement provides guidance for cost
transfers on NIH grants, including a 90 day timeframe to
complete.
NCURA 51st Annual Meeting, October 2009
20
Managing Spending on Awards

Cost Transfer “RED FLAGS”





Transfers older than 90 days
Transfers in the last month of the award or after
the award has expired
Round numbers!!
Explanations that raise more questions than
answers.
Overdrafts from one sponsored project to
another
NCURA 51st Annual Meeting, October 2009
21
Managing Spending on Awards

Cost Overruns

Cost Overruns happen for a variety of reasons



Sponsor is slow to send additional year funding
Principal Investigator assumes new funds are
coming
Lack of management of accounts at department
level
NCURA 51st Annual Meeting, October 2009
22
Managing Spending on Awards

Cost Overruns





Serious problem that must be managed by the central
accounting office
Budget cuts of state funds may exacerbate the problem
Staff turnover and lack of training in departments can add
to the problem
Business Managers may fear repercussions if they tell the
PI to stop spending
Establish a policy and stick to it!
NCURA 51st Annual Meeting, October 2009
23
Best Practices on Managing Spending

How Overspending is Managed

University of Michigan



Monthly status reports are sent to departmental
administrators
A published policy has been established to
dictate timing of write off to Dean’s account
Overspending not always a bad thing
NCURA 51st Annual Meeting, October 2009
24
Best Practices on Managing Spending

How Overspending is Managed

Broad Institute



Overrun reports are distributed monthly
OSR administrator reviews with department/lab
administrator and/or PI
OSR has responsibility for removing/covering
deficit; allocating appropriately or moving overrun
to discretionary funds
NCURA 51st Annual Meeting, October 2009
25
Best Practices on Managing Spending

How Overspending is Managed

Caltech




Very de-centralized
Grant managers have access to account
information; in addition, central administration
monitors
Monthly meetings between central and
departmental administrators
Deficits are (eventually) written off to the
department
NCURA 51st Annual Meeting, October 2009
26
Overview of OMB Circular A-21

Definitions – Key Terms


OMB – Office of Management and Budget
 Issues principles for determining costs applicable to R&D, training,
and other sponsored work performed under grants, contracts and
other cost reimbursable agreements with the Federal government.
Cognizant Agencies
 Responsible for negotiating and approving F&A rates and auditing
to ensure that institutions are applying cost principles on a
consistent basis.
 Two primary agencies:
Department of Health and Human Services (DHHS)
Office of Naval Research (ONR)
NCURA 51st Annual Meeting, October 2009
27
Overview of OMB Circular A-21

Definitions – Key Terms

Direct Cost



Facilities and Administrative (Indirect) Cost



Can be identified specifically with a particular project, program, or activity of an
institution
Examples: Salaries, Benefits, Materials, Animal Care Costs, Supplies and Services
Incurred for common or joint objectives; cannot be easily identified to a particular
project, program, or activity of an institution
Examples: Depreciation (Building, Renovations, Equipment), Interest, Operations and
Maintenance, Library, Administration costs
Allocation Base(s)

Common measurable base(s) used to allocate F&A costs
 Examples: Space (square footage), Modified Total Direct Cost (MTDC), FullTime Equivalents, Salaries and Wages
NCURA 51st Annual Meeting, October 2009
28
Overview of OMB Circular A-21

Definitions – Key Terms

Modified Total Direct Cost (MTDC)



Distribution base consisting of salaries, fringe benefits, materials, supplies,
services, travel, subcontracts up to first $25,000 of each
Examples of items excluded from MTDC are Equipment, Patient Care ,
Subcontracts greater than $25,000, and Tuition
Distribution Base (Direct Costs) – Major Functional Activities




Instruction: teaching and training activities including departmentally funded
research
Organized Research: research and development activities that are
separately budgeted and accounted for including sponsored and university
funded research
Other Sponsored Activities: performance of sponsored work other than
organized research and instruction
Other Institutional Activities: residence halls, dining halls, athletics,
ancillaries
NCURA 51st Annual Meeting, October 2009
29
Overview of OMB Circular A-21

What the Cost Principles Do:

Requires that a cost:






Be allowable
Be allocable
Be reasonable (prudent person test)
Be treated consistently
Be necessary to perform the program
Be permissible under the law
NCURA 51st Annual Meeting, October 2009
30
Overview of OMB Circular A-21

Allowable

Section J of Circular A-21
Currently describes 54 types of costs
Alphabetical order
For some costs, also specifies approval
requirements, documentation and other provisions
NCURA 51st Annual Meeting, October 2009
31
Overview of OMB Circular A-21
Examples of Unallowable Costs per A-21
(Cannot be
charged against Federal agreements, used as cost sharing, included in
service center rates or placed in the F&A cost base)
Unallowable Objects
Unallowable Activities
(Something you buy, a line item)
(something you do)





Organized fund raising
Lobbying
General public relations &
alumni activities
Student Activities
Managing investments
solely to enhance income






Advertising
Alcoholic beverages
Entertainment
Fines & penalties
Moving costs if employee
resigns within twelve
months
Certain recruitment costs
NCURA 51st Annual Meeting, October 2009
32
Overview of OMB Circular A-21
Allocable

•
Costs Must be Assigned to a Project (or Cost
Objective) in Proportion to the Benefit
Received.
•
•
•
Actual
Allocation on a Reasonable Basis
Costs Allocable to a Project may not be Shifted
to Another Project to Eliminate Deficits or Other
Reasons of Convenience.
NCURA 51st Annual Meeting, October 2009
33
Overview of OMB Circular A-21

Reasonable
“A cost is considered reasonable if the nature
of the goods or services acquired, and the
amount involved reflect the action that a
prudent person would have taken under the
circumstances prevailing at the time the
decision to incur the cost was made.”
OMB Circular A-21 C3.
NCURA 51st Annual Meeting, October 2009
34
Overview of OMB Circular A-21

Reasonable
Major Considerations:
• Is the cost required by law or within terms and
conditions of sponsored award?
• Is the cost necessary?
• The Prudent Person Test
• Consistent with institutional policies/practices?
• Would you buy this item and pay this price if you
had to personally pay for it?
NCURA 51st Annual Meeting, October 2009
35
Overview of OMB Circular A-21

Consistent


Costs Must be Treated Consistently in
Estimating, Accumulating and Reporting Costs
(CAS 501)
All costs incurred for the same purpose in like
circumstances are either direct costs only or
F&A costs only with respect to final cost
objectives. (CA 502)
NCURA 51st Annual Meeting, October 2009
36
Overview of OMB Circular A-21

Consistent - What Costs are Most at
Risk?






Clerical and Administrative Costs
Office Supplies
Local Phone Charges
Memberships
Postage
Equipment Maintenance
NCURA 51st Annual Meeting, October 2009
37
Overview of OMB Circular A-21

Consistent - Why is it a Problem to
Charge These Costs as a Direct Cost?


Each of These Cost Categories are Included in
The Departmental Administration Component of
Universities F&A Rates (Generally in Large
Amounts).
Economic Factors May Preclude Doing the
Right Thing
NCURA 51st Annual Meeting, October 2009
38
NCURA 51st Annual Meeting, October 2009
39
F&A Rate Application
On Campus Research Award
$100,000
F&A Negotiated Rate
51%
Base
MTDC
Budget:
Salaries and Benefits
$45,000
Equipment
10,000
Supplies
5,000
Subcontract
40,000
Total Direct
$100,000
F&A (75,000 x 51%)
38,250
Total
$138,250
NCURA 51st Annual Meeting, October 2009
40
F&A Rate Application

Items to Consider:




Life of the Award
Retroactive Adjustments
Your F&A Negotiation Agreement with the
Federal Government
Sponsored Agreement Terms and Conditions
NCURA 51st Annual Meeting, October 2009
41
Cash Management

Billing

Standardize billing when possible




Work with Pre-Award office to eliminate special condition billing
and the need to provide back-up with each invoice.
Create attributes in the accounting system to
allow for meaningful reports to track billing
Develop a report to verify ALL accounts have
been billed
Establish attributes in system to identify
frequency of reporting, forms & special
instructions
NCURA 51st Annual Meeting, October 2009
42
Cash Management

Letter of Credit Management



Develop a report or system that allows you to
draw only up to the award amount and not
overruns
If possible draw actual expenditures rather than
relying on estimates
Make sure the reconciliation process for letter of
credit accounts is accurate and ties to reports
sent to the government
NCURA 51st Annual Meeting, October 2009
43
Cash Management

Special Considerations


Small start-up for profits, venture capitalist
Research Agreements include







Terms and Conditions acceptable to institution
Precise scope of work
Clear payment clause
Deliverables defined
Consistency between clauses
Monitor accounts receivable closely
Create internal list of “high risk” sponsor’s
NCURA 51st Annual Meeting, October 2009
44
Collections


Develop or purchase a system to track
receivables.
Make sure ALL receivables are tracked in
the system, including “automatic” or
scheduled payments
NCURA 51st Annual Meeting, October 2009
45
Collections


Reconcile A/R to accounting system on a
regular basis
If departments must be involved in the
invoicing, make sure the central office
approves the invoice and establishes the
A/R

Regardless of who prepares the invoice, make
sure all payments are directed to the Central
Accounting Office for deposit
NCURA 51st Annual Meeting, October 2009
46
Collections



The “Send and Hope” collection process is not
effective!!!
Establish standard dunning notices and send
them on a regular basis.
Set goals for collections



Consider establishing a collection person or team to deal
with past due accounts
Document everything
Develop a plan of attack (e.g. big $ first or small
corporations first, etc.)
NCURA 51st Annual Meeting, October 2009
47
Subrecipient Monitoring
Develop a policy
 Have clearly defined roles





PI
Department
Central Administration
Risk Assessment

Educational vs. Industrial vs. Foreign
NCURA 51st Annual Meeting, October 2009
48
Subrecipient Monitoring




Develop good contract templates
Have system in place to monitor
appropriateness of invoices
Have PI approve invoices before paying
Remember that as prime recipient you are
ultimately responsible
NCURA 51st Annual Meeting, October 2009
49
Subrecipient Monitoring




Develop process to review subrecipients on
federal awards on an annual basis
For all subrecipients on federal awards, verify that
an A-133 audit was completed, if applicable
Develop a process to followup with a subrecipient
if they had any audit findings related to your
award
Develop a process to provide oversight of any forprofit or foreign subrecipients on federal awards
due to the potential of higher risk
NCURA 51st Annual Meeting, October 2009
50
Cost Sharing
 Develop
a policy
 Understand



different categories
Mandatory
Voluntary committed cost sharing
Voluntary uncommitted cost sharing
 Communicate/Train
NCURA 51st Annual Meeting, October 2009
51
Cost Sharing
 Accounting
& reporting
Separate accounts
 Same account through object codes

 Proactive
management through out
life of award
NCURA 51st Annual Meeting, October 2009
52
Best Practices for Cost Sharing
 University



of Michigan
Proposal Approval Form (PAF) requires
departmental commitment at proposal stage
Companion account established at award set
up to track cost sharing expenses
Policy that ALL quantified cost sharing in
proposal is “mandatory”
NCURA 51st Annual Meeting, October 2009
53
Best Practices for Cost Sharing
 Broad
Institute

Cost sharing must be approved at proposal
stage

When awarded, it is


accounted for separately in its “own” account
treated uniformly, consistent
NCURA 51st Annual Meeting, October 2009
54
Best Practices for Cost Sharing
 Caltech



Must be clearly identified at proposal stage
Cost share account set-up at award initiation
Reports available to central and departmental
administrators to help monitor if cost sharing
effort commitments are on target
NCURA 51st Annual Meeting, October 2009
55
NIH Salary Cap




Limits the amount of direct salary
Pay scale changes January 1 each year
Monthly rate – Keep in mind for Academic
Year and Summer Salary
Have a process in place to track
http://grants.nih.gov/grant/policy/salcap_summary.htm
NCURA 51st Annual Meeting, October 2009
56
Program Income
 Definition
Gross income earned by a grantee, a
consortium participant, or a contractor under a
grant that was directly generated by the grantsupported activity or earned as a result of the
award.
NCURA 51st Annual Meeting, October 2009
57
Program Income

Examples of Program
Income







Income from fees for services
performed such as laboratory tests
Money generated from the use, sale
or rental of equipment purchased
from project funds
Proceeds from the sale of supplies
or equipment purchased with
project funds
Proceeds from the sale of software,
tapes or publications
Income from the sale of research
materials such as animal models
Fees from participants at
conferences or symposia
Royalties from patents and
copyrights

What is not Program
Income




Interest earned on advances of
federal funds
Receipt of principal on loans,
credits discounts or interest
earned on them
Taxes, special assessments,
levies, and fines raised by
government recipients
Patient care credits
NCURA 51st Annual Meeting, October 2009
58
Program Income

Proposals

NIH requires that program income be
estimated at the time of proposal submission

In other instances, it is a good idea to
determine as soon as possible so it can be
isolated.
NCURA 51st Annual Meeting, October 2009
59
Program Income
 Accounting for Program Income
 Isolate so it can be identified
 Separate account is ideal
 Treatment may vary by agency
 Will be specified in grant/contract
 May not be addressed in non-federal projects
 Most Federal agencies require reporting with
financial report
NCURA 51st Annual Meeting, October 2009
60
Effort Reporting

Definition

Time and effort reporting is a Federal
requirement (OMB A-21. Section J(10)) to ensure
that individuals confirm “after-the-fact” any effort
they have expended on federally funded
activities.
NCURA 51st Annual Meeting, October 2009
61
Effort Reporting
CHALLENGES
Salary Cost
Transfers
Faculty Work
Week
Proposal
Preparation
Costs
Appointment /
Annual Salary
Letters Unclear
Effort
Reporting
Research Faculty
What’s in & What’s
Out of Effort?
9 Month
Faculty
NCURA 51st Annual Meeting, October 2009
62
Effort Reporting
What’s In









What’s Out
Research
Instruction
Administration
Service
Proposal Preparation (paid from
University Sources)
Lectures About Specific Aspects of
Your Sponsored Project
Reports & Articles Related to the
Sponsored Project
Conferring with Students Working
on the Project
Attending Meetings Required to
Conduct Work on the Project





Any Outside Activity for Which
Compensation is Paid (or for Which
You Would Normally Expect Pay)
Outside Consulting
Volunteer Community or Public
Service
Interdepartmental Consulting
Sponsor Review Panels or Other
Advisory Activities for Federal
Sponsors
NCURA 51st Annual Meeting, October 2009
63
Effort Reporting

Red Flags




100% Effort on Sponsored Projects
0% Effort for PI’s
Summer Salary
Supplemental Payments
NCURA 51st Annual Meeting, October 2009
64
Effort Reporting

Issues to Consider:





Make sure reports are completed by individual or
someone with suitable means of verification
Be careful to certify actual effort rather than budgeted
amount or payroll charges
Manage system to ensure reports are completed in a
timely manner to avoid late certifications
Consider NIH salary cap as applicable
Make sure cost shared effort is included in 100% and
certified
NCURA 51st Annual Meeting, October 2009
65
Best Practices for Effort Reporting
 University




of Michigan
All are required to sign their own certification
statement
Process is audited and outlying departments
are contacted to review process
Process handled through Sponsored
Programs Office
Web based application
NCURA 51st Annual Meeting, October 2009
66
Best Practices for Effort Reporting
 Broad



Institute
Plan Confirmation System
Effort captured via payroll system
Monthly certification
NCURA 51st Annual Meeting, October 2009
67
Best Practices for Effort Reporting

Caltech





Effort reports are certified by someone with
suitable means of verification (PI or supervisor)
Paper reports, developed internally
Distributed and collected twice a year
Report data comes from Payroll system
Reports include information on effort commitments
made in award
NCURA 51st Annual Meeting, October 2009
68
Close Out of Awards

Potential Solutions to Meeting Deadlines





Send notices of expiring awards well in advance
of the expiration date
Create reports to track closing awards
Require written request from the department if
deadlines cannot be met
Develop a close out policy
“Freeze” award once final financial report is sent
NCURA 51st Annual Meeting, October 2009
69
Close Out of Awards

Financial Aspects of Close Outs







Departmental Signoff on Final Expenditures
Verification of Cost Sharing
Verification of F&A
Financial Status Report
Final Invoice or Draw
Fixed Price Agreements Residual Balances
Close Account in General Ledger
NCURA 51st Annual Meeting, October 2009
70
Close Out of Awards

Non-Financial Aspects of Close Outs



Technical Reports
Property Reports
PI Relocation
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Best Practices for Close Out
 University




of Michigan
90 Day notice e-mail
Appointment follow-up letter
Tracking system - metrics
Meet with departments
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Best Practices for Close Out
 Broad



Institute
Closing Notice sent 60 days prior to end of grant
requesting close out info or extension request.
Monitor changes – follow-up – track invoices
Monthly meetings for review and updates
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Best Practices for Close Out
 Caltech
90 day notification
 Tracking system
 Monitored by central administration

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Audits

Central Point of Contact for Audit Coordination



Consider policy for audit protocol
Make campus aware of who to contact if
contacted directly by an auditor
What kind of audit is it and who are the auditors?


Audit vs. investigation
Federal vs. Internal vs. Financial auditors
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Types of Audits

Pre-award ($1mil or greater)

Financial Statement

OMB A-133

Program

Disclosure Statement

F&A Cost Proposal

Procurement System Review

Property System Review
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What Auditors Test For:









Allowability of Costs
Cost Transfers
Cost sharing
Effort reporting
Program Income
Timeliness of Reports
Sub-recipient Monitoring
F&A rate and calculation
Everything else…
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Keys to A Successful Audit







Central point of contact
Organized files
Documentation for expenses
Appropriate approvals
Audit trails
Knowledge of policies and regulations
Brief staff on audit process and
assign a point of contact
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Audit Management






Don’t assume the auditor has complete
knowledge of regulations – they don’t!
Understand all auditor’s questions
If you are not sure - check it out
Don’t ramble or provide additional
information – short, concise answers
Keep track of questions and responses
Always accompany the auditors when they
speak to the PI
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Training

The key to ensuring proper accounting for
sponsored projects is training



Department administrators MUST be trained in
the basics of accounting, OMB circulars, and
institutional policies and procedures.
Training programs do not have to be elaborate
but must be offered repeatedly to ensure that
staff is aware of changing regulations
Training must also be done for pre/post-award
offices
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Best Practices for Training
 University




of Michigan
Research Administrators’ Instructional
Network (RAIN)
Research Administrators’ Network (RAN)
Customer Service one-on-one training
Additional Central Office Training Programs
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Best Practices for Training

Broad Institute

Administrator Orientation and Training

New system training

External resources such as NCURA;
Fundamentals, Neighborhoods, Listserves
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Best Practices for Training

Caltech




Quarterly Research Administrators Forum
Just-in-time training for new policies, procedures and
systems
On-going refresher courses
Relaying audit findings and corrective action plans to
campus
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Web Sites

University of Michigan



http://www.umich.research.edu/
http://www.umich.edu/~finops/
Broad Institute of MIT and Harvard
http://www.broadinstitute.org/

Caltech

http://www.caltech.edu
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How to Contact Us

Rob Barbret
University of Michigan
Associate Director, Financial Operations
734 764-9593
rbarbret@umich.edu

Vivian Holmes
Broad Institute of MIT and Harvard
Assistant Director, Sponsored Research
617/714-7132
vholmes@broad.mit.edu

Tracey Fraser
Caltech
Senior Director, Financial Services
626-395-2540
tracey.fraser@caltech.edu
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