New UVM Policies and Procedures Affecting Grants: Advance Accounts, Cost Transfer, and Residual Balance Sponsored Projects Training Program December 8th, 2011 Beverly Blakeney, Ruth Farrell, Michael Meunier Welcome An introduction to the presenters and the topics. Time line and next steps for implementation of these policies and procedures. Sponsored Projects Training Program Learning Objectives Increase awareness of upcoming changes in cost transfer policy and two new, separate procedures that will soon be in place. Help participants understand new operational practices that they will have to plan for. Sponsored Projects Training Program Reminder – the Cost Principles Allocable Allowable Reasonable Consistently charged Sponsored Projects Training Program Advance Account Procedure a.k.a Guaranteed Funding Advance Account – What? Creation of a sponsored project chart string before an award document is received or accepted from the sponsor Sponsored Projects Training Program Advance Account – Why? Need to start the work Allows PIs and Departments to record and track expenditures in appropriate chart string Reduces salary and non-salary cost transfers Eliminates re-work for principal investigators, department administrators, and staff in central offices Sponsored Projects Training Program Evaluating Risk Written confirmation from sponsor Sponsor’s history with UVM Negotiation risks Sponsored Projects Training Program What needs to be in place? –How? Department or unit must assume risk Written confirmation from sponsor Proposal must be fully routed and approved Regulatory requirements must be satisfied ◦ IACUC, IRB, IBC, COI Competed request form Modified budget (optional) Sponsored Projects Training Program Limitations Request 90-180 days Can limit dollar amount Any limitations of the sponsor Sponsored Projects Training Program Responsibilities PI – initiating request, collecting required documents, spending within the constraints of AA Unit – submit request, assumes fiscal risks, monitors, ensures expenses and encumbrances conform to advance account duration VP or Dean of unit – assumes financial risk SPA – advise on potential risk, confirm all regulatory approvals are obtained, approve AA and establish chart string, provide training Sponsored Projects Training Program What happens next? Award received and accepted SPA completes the set up process Billing can occur Or – no award is received charges need to be moved Sponsored Projects Training Program Resources Monthly report PS Query ◦ UV_GM_FINDINGAWDTHRUREFAWD ◦ It can be run on an ad hoc basis, by department number, award number, reference award number or wide open using wildcards. The search fields are not case sensitive. ◦ Can be used to locate an award if you only know the sponsor's award number ◦ Can be run at any time to identify all advance accounts by department or for the whole university Sponsored Projects Training Program Questions? . Sponsored Projects Training Program Cost Transfers Involving Sponsored Agreements Policy - Revision Update Michael Meunier Cost Accounting Services (CAS) 1:30-2:30 Memorial Lounge December 8, 2011 Cost Transfer Policy Topics Policy Review Process Cost Transfers at UVM Key Policy Changes Cost Transfer Form Policy current status: Campus wide policy comments on this policy are currently being considered. Sponsored Projects Training Program Cost Transfer Definition A cost transfer is the assignment of an expense to a sponsored agreement that was initially recorded elsewhere in the University’s general ledger. ◦ Removal of an expense from a sponsored agreement to a nonsponsored chart string will continue to require an explanation and appropriate approvals. Sponsored Projects Training Program Cost Transfer Policy – Review Process Profiled university cost transfer activity Reviewed Grant Lifecycle Committee Report (August 2009) Benchmarked other University policies/procedures Analyzed key sponsor specific regulations ◦ HHS, NIH, NSF, Federal Formula grants Reviewed external audit reports and recommendations Solicited feedback from Academic Business Managers Sponsored Projects Training Program Cost Transfers at UVM UVM has significantly more cost transfers, particularly late cost transfers, than similar Universities • Allowability concerns (red flag to auditors) • Inefficient use of University resources • Fiscal management of sponsored agreements Sponsored Projects Training Program Cost Transfer Policy – Key Changes Accountability statement Minimizing cost transfers Timeliness Approvals Unallowable Expense Transfer Authority Sponsored Projects Training Program Key Policy Changes - Accountability All University personnel are expected to be aware of and comply with this University policy and the principles and requirements listed below. Confirmed violations will result in disciplinary action. In some instances, civil claims and criminal charges may also result. Sponsored Projects Training Program Key Policy Changes – Minimizing Cost Transfers • Charge only allowable expenses to sponsored agreements • Utilize advance accounts • Minimize posting expenses to department suspense • Quarterly meetings with PIs (Effort, Non-salary expenses) • Submit timely and relevant salary distribution changes • Reallocate PurCard expenses within University deadlines Sponsored Projects Training Program Key Policy Changes – Timeliness 1) Identifying errors in a timely manner • Monthly verification of financial transactions (PMBR) • Department Suspense Review 2) Timely Cost transfer Submissions • < 90 days after original accounting date (GL) • Salary transfers included (no more 30 day grace period) • Department submission date is official submission date Note: NIH only allows cost transfers within 90 days after the error was discovered. Sponsored Projects Training Program Key Policy Changes – Justification / Documentation Justification • Detailed explanation • Independent reviewer understanding • Subject to audit (No email threads!) Supporting Documentation • Current Salary Distribution Form • Original Additional Pay Voucher (APV) • Project monthly budget report (non-salary xfers) • List of business meal attendees • Certified Effort Report w/ changes Sponsored Projects Training Program Key Policy Changes – Untimely Submissions Untimely Cost Transfer Submission (> 90 days) ◦ Original General Ledger accounting date ◦ Cost transfer requests > 90 days after the error is discovered is unallowable (NIH policy) Additional Written Justification Required ◦ Lateness ◦ Extenuating circumstances ◦ Corrective action to prevent future occurrences Sponsored Projects Training Program Key Policy Changes – Required Approvals Department Approval • No one person has complete control over all aspects of the cost transfer submission (Preparer, Approver) Timely Cost Transfer Central Office • • Cost Accounting Services (CAS) Sponsored Project Administration (SPA) (< 90 days) Salary/Wages Non-Payroll Untimely Cost Transfer Request (> 90 days) • Principal Investigator signature is required • Vice President signature is required Sponsored Projects Training Program Key Policy Changes – Transfer Authority of Unallowable Expenses Non-Payroll Expenses • SPA has authority to transfer expenses to department general fund account Uncertified Payroll Charges • CAS has authority to transfer non-certified payroll expenses to the employee’s home department general fund chart string. Note: Sponsored Projects Expense Transfer policy will be eliminated. Sponsored Projects Training Program Cost Transfer Procedure & Form Required for all cost transfer submissions • • • • Salary Distribution Changes Additional Pay Vouchers Wage Transfers Non-Payroll cost transfers (email form to SPA) Cost Transfer Procedure/Form • Standard Form • Salary Distribution Form Sponsored Projects Training Program Cost Transfer Forms Sponsored Projects Training Program Cost Transfer Policy Summary - Key Changes Minimize cost transfers (Advance accounts, Prospective payroll distribution changes, timely PurCard transactions) Timeliness (< 90 days) (Monthly PMBR review, Sufficient justification) Untimely Cost Transfers ( > 90 days) (Additional justification and approvals, Corrective action) Cost transfer procedures/form (Updated, standardized) Sponsored Projects Training Program Cost Transfer Policy Changes - Questions/Feedback - Sponsored Projects Training Program Residual Balance Procedure What is a residual balance? Residual balance: For fixed-price agreements only, this is the term for any funds remaining after all charges have been incurred to complete the project and all project activities are complete. Sponsored Projects Training Program Current practice Residual balances remain in sponsored project restricted chart string. Project end-date is recorded as “indefinite.” P.I. continues to expend funds for additional research. Sponsored Projects Training Program Current practice issues Doesn't recognize the unrestricted nature of these funds. Cost considerations, such as required effort and sponsor allowable costs are no longer applicable. If federal, remains on Schedule of Federal Awards and subject to audit. Sponsored Projects Training Program New procedure for residual balances Residual balances remaining at the conclusion of sponsored project funded by a fixed price agreement, less appropriate Facilities and Administrative (F&A) costs, will be transferred to an unrestricted chart-string for the Principal Investigator’s use. Sponsored Projects Training Program Conditions for transferring residual balances to department accounts All deliverables have been received and accepted by the sponsor. All costs for the project have been posted to the project’s chart-string. All payments for the project have been received from the sponsor. Sponsored Projects Training Program Conditions for transferring residual balances to department accounts The residual balance must be more than $200 direct. If the residual direct cost balance is greater than 20% of the direct costs awarded, an explanation detailing why the actual direct costs were substantially less than anticipated is required. If the residual direct cost balance is more than $5,000, the intended use must be described. Sponsored Projects Training Program Process SPA staff will follow the standard award closeout procedures for all awards within 90 days of end-date. For balances greater than $200, SPA will contact the Principal Investigator and academic unit administrator for a residual funds chart-string request form. Once all conditions have been met, SPA will transfer direct funds to unrestricted account. Sponsored Projects Training Program Re-Cap Direct cost residual funds on fixed-price agreements will be transferred to unrestricted chart string for PI use. Certain conditions have to be in place for this to occur (project complete, all expenses posted, large balances analyzed). SPA will request the completion of a request form during close-out if funds remain. Sponsored Projects Training Program ? Questions?? Sponsored Projects Training Program