GRANTS: CRADLE TO GRAVE ALUMNI CENTER BALLROOM MAY 6, 2014 Post Award Processes & Effort Reporting Roberta McManus Associate Director – Sponsored Research Administration 2 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 3 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 work Collaboration/subcontracting to other individuals/institutions • Monitoring of activities - documentation Status reports Technical reports • Payments will be held if not submitted timely • Hold up future awards!! 4 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 5 Post Award Activities • 90 days prior to award end New funding increment? Request extension if needed/allowed Notify university grants officer in accordance with timelines established 6 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 requirements Obligations 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 7 Award Closeout • SOW complete and final reports submitted • Expenditures are complete: All charges incurred during project period are posted Avoid late cost transfers Charges posted allowable Necessary 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 8 Compliance Requirements • Federal New Federal guidance issued December 2013 Effective for awards/increments issues on/after December 26, 2014 OMB 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.html Agency specific requirements Terms and Conditions of award • Non Federal Terms and Conditions rule!! • FSU SR Related Policies and Procedures http://www.research.fsu.edu/contractsgrants/policypro.html# 9 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” 10 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 11 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 12 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 13 Cost Transfer Policy • Ensure that funds are properly managed • Indicators of inadequate fiscal monitoring Frequent cost transfers Late cost transfers Inadequately documented or justified cost transfers • Examples of improper/unallowable cost transfers Utilizing unexpended funds Moving overrun on one project to another project Moving unallowable costs on one project to another project Circumventing award restrictions Reimbursing a temporary “loan” of funds from another project 14 Cost Transfer Policy • Proper cost transfers The transfer represents an adjustment for an erroneous charge Split purchase • Timeliness Essential to evidence sound fiscal management Monthly reconciliations!!!!! • Policy Payroll/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 15 Cost Accounting Standards (CAS) • FSU is required to disclose “costing practices” in a formalized document (Disclosure Statement-2) • Describes how FSU treats Direct F&A costs • Facilities • Administration 16 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 17 CAS Exception Process • Must be documented for all federally-funded awards • Pertains to direct charge costs that are normally treated as indirect costs Personnel Non-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 18 Cost Sharing • Policy at http://www.research.fsu.edu/contractsgrants/costs haring.html • Procedures at http://www.research.fsu.edu/contractsgrants/docu ments/csprocedures.pdf • Definition = Costs not borne by FSU • Criteria for tracking/reporting Committed – Mandatory vs. Voluntary Committed Must account for and report “Project Enhancement” Do not have to account for and report 19 Cost Sharing • Include in the proposal budget Cost Share Commitment Form Signed by Chair/Dean/Director • Cost Share budgets are set up in OMNI Sponsored 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 20 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.) 21 Budget & Expenditure Monitoring • Award is to the University…however • PI responsible for ensuring expenditures benefit the project Timing 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 reports Personnel – staff charged/encumbered Non-personnel 22 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 entries Cost Transfer Justification Form • All interdepartmental requisitions Sales between departments (stockrooms, machine time, etc.) 23 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 Balance Direct cost budget check • Budget category line item • FDP/RTC 24 SRA Review of Expenditures • Account or Job Code Appropriate for nature of expense • Allowable Remember OMB Circular A-21! Terms and Conditions support expense 25 Collaboration with Other Researcher • Often included in proposal Institution 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) 26 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 budget Expenditures (costs incurred) Encumbrances (POs, T-Auths, personnel appointments) Not encumbered (future personnel appointments, tuition, rent, F&A) 27 PI Resources 28 Training Opportunities • CReATE – Compliance and Research Administration Training and Education Next session Fall 2014 New Federal guidance • SRA Certificate Series Curriculum geared toward support staff Hands on tools Summer schedule in process Schedule posted at http://www.research.fsu.edu/contractsgrants/workshops.html 29 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 Procedures Forms Funding Resources OMNI Information Training Information Email/Newsletter Services (recommend getting on these list serves) 30 Web Resources • Controller’s Office (http://www.vpfa.fsu.edu/control/) General Accounting Payroll Services Property Accounting Accounts Payable Travel • 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) 31 Contact Information SRA Assignment Sheet http://www.research.fsu.edu/contractsgrants/documents/sta ff.pdf 32 QUESTIONS