RA_Townhall_102914 - UCSF Controller`s Office

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Controller’s Office
Research Administration Town
Hall
Wednesday, October 29, 2014
10:00-12:00 PM
HSW-301 w/ a live broadcast to Genentech Hall, Byers
Auditorium at Mission Bay & Room 116 at the Fresno
Campus & Live Webcast
Contracts and Grants Accounting
Agenda
 Introduction of New AVC, Research Administration –
Marge O’Halloran
 Coverage Analysis – Eileen Kahaner and Jacquie
Eichhorn
 NOT-OD Updates – Joyce Abe
 Uniform Guidance Update – Nilo Mia
 Final Invoice Preparation – Dan Wikert
 Clinical Trial Post Award Topics – Michael Grafton
 Post Award Hot Topics – Michael Grafton and Jean
DeMartini
 Compliance Update – MC Gaisbauer
 CGA Survey and Contact Process – MC Gaisbauer
Controller’s Office
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Introduction of new
AVC, Research Administration
Controller’s Office
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Update:
Clinical Trial Coverage Analysis
UCSF Clinical Enterprise Compliance Program
(CECP)
4
Agenda
Introductions
What is a Coverage Analysis (CA) and why is it
important
Who performs CAs at UCSF
Your role
Controller’s Office
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UCSF Clinical Enterprise Compliance Program
 Mission
 Promote a culture of compliance with applicable laws, rules,
regulations
 Provide oversight, guidance, and tools to detect, deter, and
resolve non-compliant behavior
 Establish an environment that empowers and expects
individuals to address conduct that does not conform to the
applicable standards
 Support UCSF Mission by reducing organizational risk
 Scope
 Clinical activities, including clinical research billing
 Tools
 Training, address questions, review policies/SOPs
 Perform reviews
 Oversee corrective actions
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Process
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What is a Coverage Analysis?
 Focused review of all clinical trial-related documents to
determine who is financially responsible for all items and
services provided to the research subjects over the course of
the study
 Process aligns the Protocol, Clinical Trial Agreement, Informed
Consent (ICF), Budget
 Creates a reference that all subsequent billing and invoicing
decisions should use
 Study team, post-award, patient billing
 ICF costs section
 UCSF CA mandate as of June 1, 2013
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Some Principles of CA Development
Coverage analysis is based on billing rules
 Medicare rules typically applied
 More well defined
 Most commercial payors follow, even for pediatrics
Charging for an item does not necessarily
mean that item is reimbursable
FDA approval does not guarantee
reimbursement
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Why is the CA Important?
Respond to government attention re CRB
 Industry trials and federal grants
More accurate assessment of trial costs
 Improves budgeting
 UCSF cost recovery per OP mandate
Allows accurate ICF for expected costs
Accurate billing to sponsor and payors




Single reference for study teams, post-award, billers
Maintain sponsor and participant trust
Reduces need for “back-end” corrections
Demonstrates due diligence to bill accurately reducing
fines or penalties if mistakes are made
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Multiple Groups Perform CAs
CA owner depends on type of trial
http://hub.ucsf.edu/ca-budget-billing
CTBSC: [email protected]
Cancer Center: [email protected]
Division of Cardiology: [email protected]
Budgeting also performed by multiple parties
Non-industry Sponsored Clinical Trial - RMS
Industry Sponsored Clinical Trial - ITA
Cancer Center - ITR
Division of Cardiology - Cardiology
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Your Role
Encourage study team to seek CA early in
process – run in parallel with other
activities
Do not finalize CTA without a formal CA
Alert CECP to potential issues that
cannot be resolved through standard
processes
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Questions?
Jacquie Eichhorn, Manager Clinical Research
Billing Compliance
 [email protected]
 415-514-2576
Eileen Kahaner, Director, CECP
 [email protected]
 415-476-8642
CECP – 415-502-2790
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NOT-OD Updates
Controller’s Office
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Notable NIH Updates
NOT-OD-15-014
NOT-OD-13-097
NOT-OD-14-113
NOT-OD-14-090
NOT-OD-14-094
NOT-OD-14-095
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Reminder: NOT-OD-15-014
 http://grants.nih.gov/grants/guide/notice-files/NOT-OD-15014.html
Guidance about
 NIH Type 5 Progress Reports (annual progress reports)
• Implements
 Effective October 17, 2014 NIH requires that all type 5
progress reports be submitted using the Research
Performance Progress Report (RPPR) module in eRA
Commons
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Reminder: NOT-OD-13-097
 http://grants.nih.gov/grants/guide/notice-files/NOT-OD-13097.html
Guidance about
 Graduate students/undergraduate students roles
participating on NIH-funded projects for one person
month or more
• Implements
 Effective October 2014 NIH requires eRA Commons IDs for
all graduate and undergraduate student roles reported on
annual progress reports (RPPRs)
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Reminder: NOT-OD-14-113
 http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14113.html
Guidance about
 Individual Development Plans (IDP) for graduate students
and postdoctoral researchers supported by NIH awards
• Implements
 Effective October 1, 2014 Research Performance Progress
Report (RPPR) are required to include a report on the Use
of IDPs in Section B, Question B.4.
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REMINDER: NOT-OD-14-113, continued
The Graduate Division has posted information
on IDPs and template language for RPPRs on
their website:
 You can get the information on IDPs at:
https://career.ucsf.edu/grad-studentspostdocs/myIDP
 Template language for RPPRs is located at:
https://career.ucsf.edu/sites/career.ucsf.edu
/files/PDF/Reporting%20Use%20of%20the%
20IDP.pdf
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NOT-OD-14-090 and NOT-OD-14-133
 http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14090.html
Guidance about
 Update to PA-14-150 (F30) NRSA Individual Predoctoral
Dual-Doctoral Degree Fellowship
• Implements
 Requirement to upload “Additional Educational
Information” under Other Attachments in the Other
Project Information section of the application
 Applications submitted without this attachment will be
considered incomplete and rejected
Controller’s Office
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NOT-OD-14-094 and NOT-OD-14-134
 http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14094.html
Guidance about
 Update to PA-14-147 (F31) NRSA Individual Predoctoral
Fellowship
• Implements
 Requirement to upload “Additional Educational
Information” under Other Attachments in the Other
Project Information section of the application
 Applications submitted without this attachment will be
considered incomplete and rejected
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NOT-OD-14-095 and NOT-OD-14-135
 http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14095.html
Guidance about
 Update to PA-14-148 (F31-Diversity) NRSA Individual
Predoctoral Fellowship to Promote Diversity in HealthRelated Research
• Implements
 Requirement to upload “Additional Educational
Information” under Other Attachments in the Other
Project Information section of the application
 Applications submitted without this attachment will be
considered incomplete and rejected
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Controller’s Office
OMB Uniform
Administrative
Requirements, Cost
Principles, and Audit
Requirements for
Federal Awards
Background – When, Why, Who?
 Fall 2009, Executive Order 13520 on reducing improper
payments and eliminating waste in Federal programs and
Presidential memorandum on promoting administrative
flexibility
 Set in motion the single biggest regulatory change in the
last 50 years of research administration
 In the documents, President directed OMB to work with
Executive Branch agencies and other key stakeholders to
evaluate potential reforms to Federal grants policies
 The Council on Financial Assistance Reform (COFAR) was
established in October 2011 and has led efforts to improve
delivery, management, coordination, and accountability of
Federal grants and cooperative agreements, which includes
the development of the uniform guidance
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Background – What Did COFAR Do ?
OMB Advance Notice – Spring of 2012
Proposed guidance issued February 1, 2013
Final guidance issued December 26, 2013
Federal agencies had 6 months (to June 26,
2014) to submit THEIR draft(s) of
“implementing regulations” to OMB
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Overview of UCSF Review and Campus
Coordination Process
 Meet every two/three weeks to review guidance and make
initial assessment
 Form UCSF position and stay connected with UCOP to share
concerns and stay abreast of UCOP review process
 Coordinate UCSF concerns with Council on Government
Relations (COGR)
 Establish and maintain communication plan with campus
stakeholders
 Vet concerns of Grant Reform Task Force with campus
administrators and academic community
 With stakeholders, establish campus priorities and develop
implementation plans
 Execute, track, and communicate status of implementation
processes
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Parts of UG & Who Is Reviewing It
Final Rule Section Title
Subpart A – Acronyms and Definitions
Subpart B – General Provisions
Subpart C – Pre-Federal Award Requirements
Research
Subpart D – Post Federal Award Requirements
Subpart E – Cost Principles
Subpart F – Audit Requirements
Appendices
 Notice of Funding Opportunity
 Contract Provisions
Research
 F&A Costs…for Institutions of Higher
Education
 F&A Costs…for Nonprofit Organizations
 State/Local Gov’t and Indian Tribe Service
Allocation
 Public Assistance Cost Allocation Plans
 States and Local Gov’t and Indian Tribe IDC
 Nonprofit Orgs Exempted from Subpart E
 Hospital Cost Principles
 Data Collection Form (Form SF-SAC)
 Compliance Supplement
Controller’s Office
Champion
All
NM
JR& MO
Department
All
Budget & Resource Mgmt.
Office of Sponsored
MC
NM
MC/TP
Controller’s Office
Budget & Resource Mgmt.
Controller’s Office/Audit
All
All
JR& MO
Office of Sponsored
NM
N/A
Budget & Resource Mgmt.
N/A
N/A
N/A
N/A
N/A
MC
MC
Controller’s Office
Controller’s Office
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Review Timeline
2016
Establish sub-committee
1.2
Set communication meetings every 2 weeks
1.3
Champions to develop review plan
1.4
Establish campus communication process
1.5
Send second announcement to campus (task force formed)
Review OMB Final Guidelines for campus impact
2.1
Form initial assessment
2.2
Review with sub-committee
2.3
Strategize / determine options/ priorities
2.4
Vet with stakeholders
2.5
Communicate to leadership on priorities by FYE 2014
3.0
Prioritize and create draft implementation plan schedule
4.0
Brief leadership on initial implementation plans
5.0
Revise campus communication process
6.0
Establish progress tracking process and check in with Costing Policy Group
7.0
UCSF Compliant with New Guidance
Controller’s Office
JUL
Audit Requirement
Administrative
1.1
2.0
2015
Administrative Requirements and Cost Principles
1.0
2014
2015
JAN
FEB
MAR
APR
MAY
JUN
Review and Implementation Process and Timeline
2014
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
Calendar Year
Fiscal Year
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UC Approach to Uniform Guidance, Phase One (6 months)
 Identify major issues and areas where systemwide guidance or policy will
need to be updated
 Determine key issues/approaches to inform and engage local campus
constituencies
 Issue systemwide guidance, where appropriate, and/or begin work to
update policies, as needed
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Uniform Guidance Applicability
Applicability and Dates (200.110)
 Uniform implementation date of
12/26/14 for all Subparts, except
Subpart F
 Subpart F, Audit Requirements, will be
effective the first FY beginning after
12/26/14; for UCSF, this will be FY 2016
(July 1, 2015 – June 30, 2016)
 The UG will be applicable to all NEW
AWARDS and extensions / additions to
EXISTING AWARDS with award dates on
or after 12/26/14
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Uniform Guidance Applicability
 Question: Will the Uniform Guidance changes apply
ONLY to awards made after the effective date
(December 26, 2014), or do the changes apply to
awards made earlier?
 Answer: Once the Uniform Guidance goes into effect,
it will APPLY TO AWARDS or FUNDING INCREMENTS
AFTER THAT DATE (December 26, 2014); it will NOT
retroactively change the terms and the conditions for
funds (awards) already received
 Note: Existing federal awards will continue to be
governed by the terms and conditions of that Federal
award
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Some Top Highlights and Key Issues
 200.112 Conflict of Interest
 200.301 Performance Management
 Researchers must relate Financial Data to Performance Accomplishments of the federal
award
 Researchers MUST provide COST INFORMATION to demonstrate COST EFFECTIVE
PRACTICES (e.g. – unit cost data); objective is to improve program outcomes, share
lessons learned, and spread adoption of best practices
 Higher reporting bar overall for Federal contracts
 Stronger certification language reminds signers of statutory penalties for false
certifications

NOTE: Alert your PI’s now of these requirements…
 200.303 Internal Controls
 Strong emphasis on IA as well as understanding “must” versus “should”
 Requires recipients to have strong internal controls; should be in compliance with…
 Internal Control Integrated Framework (COSO)
 The Federal “Green Book” – Protecting Personally Identifiable Information
 Federal statutes, regulations and conditions (Comptroller General of the U.S.)
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Some Top Highlights and Key Issues
 200.306 Cost Sharing
 Voluntary committed cost-sharing is not expected in Federal research
proposals
 Cost-sharing obligations must be included in FOA’s (Funding Opportunity
Announcements)
 Cost-sharing may not be used as a factor in the merit review of applications or
proposals
 200.307 Program Income
 200-313 Equipment
 “Conditional Title” is new; not a new concept, but designed to clarify, among
other things, Federal equipment should move with the PI if they transfer
between Universities; also clarifies that conditional title is calculated using
project costs including mandatory cost sharing
 “Percentage of Federal participation in the project costs” (A-110 required the
“percentage of Federal participation in the cost of the equipment”) and “use
and condition” (“use” is not included in A-110) are new; preliminary
assessment is that the subtle changes in terminology will NOT require systems
changes to the institution’s equipment inventory system
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Some Top Highlights and Key Issues
 200.317-326 Procurement Standards
 Effective July 1, 2016 (or FY17), but work ahead
 One year grace period before implementation
 200.330 Sub-recipient and Contractor Determinations
 New option for each Federal agency to require us to document
how we decided each transaction is either a Subrecipient versus
a Contractor
 Characteristics of a Subrecipient / Contractor have not changed
 In new agreements with Subrecipients, be certain to reference
the terms and conditions found in the new “Uniform Guidance”,
effective December 26, 2014
 If you want reports from your “subrecipient”, you must include
that requirement in your sub-award documentation
 The provisions of the prime sponsor usually flow through to the
“sub-awardee”; additional provisions may be added by the
awardee
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Some Top Highlights and Key Issues
200.331 Requirements for Pass-through Entities
 Subrecipients must be monitored to ensure that the
subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the
terms and conditions of the subaward
 The Uniform Guidance provides recommendations,
but does not specify how the pass-through entity
should conduct that monitoring
 Any monitoring would need to comply with the overall
need for sufficient internal controls to meet the
requirements in this section
 Pass-through entities must honor subrecipient
negotiated F&A rate or use 10% de minimis rate, or
negotiate one with the subrecipient
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Some Top Highlights and Key Issues
 200.332 Fixed Amount Subawards
 The uniform guidance allows for the use of fixed amount (fixedprice) subawards but:
– Only with the prior approval of the Federal awarding agency
– Only up to the Simplified Acquisition Threshold ($150,000)
 Prior approval may be inferred if the intent is included in a
proposal submission and awarded
 The $150,000 cap may be problematic for some projects
 200.343 Closeouts
 Campuses must complete final reporting, invoicing, and cash
draws within 90 days of the end of the performance period or
risk not being able to recover funds expended
 Although this requirement is not new, the Uniform Guidance
codifies it and imposes a hard stop to adjustments
 This could prove challenging in the management of subawards
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Some Top Highlights and Key Issues
 200.413 Direct Costs – Clerical & Administrative
 The Uniform Guidance allows for the direct charging of administrative
and clerical salaries, so long as certain conditions are met:
 Administrative or clerical services are integral to a project or activity
 Individuals involved can be specifically identified with the project or
activity
 Such costs are explicitly included in the budget or have the prior written
approval of the Federal awarding agency
 The costs are not also recovered as indirect costs
 A justification should be included in proposals that addresses the
criteria above to facilitate the required agency approval for these
charges
 Any post-award addition of administrative salaries to a budget would
require prior written approval of the funding agency
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Some Top Highlights and Key Issues
 200.414 Indirect Costs
 4-year extension, 1.3% UCA
 200.419 Cost Accounting Standards and DS-2
 11th hour push and cautious optimism
 200.430 Compensation – personal services
 Opportunities and challenges
 200.456 Participant Support Costs
 Now a federal-wide concept
 Are defined as direct costs for items such as stipends or
subsistence allowances, travel allowances, and registration fees
paid to or on behalf of participants or trainees (but not
employees) in connection with conferences, or training projects
 Participant support costs will be an exclusion in the MTDC base
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Some Top Highlights And Key Issues
200.461 Publication and Printing Costs
 The Uniform Guidance provides institutions
additional flexibility to charge Federal awards after
the performance period for page charges in
professional journals
 This may require a system/procedure change to
allow costs to post to an award after the
performance period
 Late charges can create issues for meeting 90 day
closeout requirement for Federal awards
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What’s next?
Phase One (Jan – Dec 2014)




Assess & analyze the Uniform Guidance
Inform the campus and discuss approaches
Issue interim guidance, as needed
Issue Assessment document
Phase Two (Jan – June 2015)
 Update guidance & policies as needed
 Update DS2s (?)
 Update training & support, as needed
Phase Three (Jul – ~Dec 2015)
 Update support systems, as needed
 Other long-horizon actions needed
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Thoughts on Implementation Planning
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Primary UCSF Grant Reform Task Force Contacts
Nilo Mia - Budget and Resource Management
Office
MC Gaisbauer - Controller’s Office
Marge O’Halloran - Research Management
Services, Office of Sponsored Research
John Radkowski - Government and Business
Contracts, Office of Sponsored Research
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Key Websites
Uniform Guidance, Title II CFR Part 200
www.ecfr.gov
Federal Register Notice with Preamble
https://federalregister.gov/a/2013-30465
Council on Financial Assistance Reform
www.cfo.gov/cofar
Questions and Concerns about the UG
[email protected]
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OMB Circulars Consolidated Into UG
 A–21, ''Cost Principles for Educational Institutions'' (2 CFR Part 220)
 A–87, ''Cost Principles for State, Local and Indian Tribal
Governments'' (2 CFR Part 225) and also Federal Register notice 51
FR 552 (January 6, 1986)
 A–89, ''Federal Domestic Assistance Program Information''
 A–102, ''Grant Awards and Cooperative Agreements with State and
Local Governments''
 A–110, ''Uniform Administrative Requirements for Awards and
Other Agreements with Institutions of Higher Education, Hospitals,
and Other Nonprofit Organizations'' (codified at 2CFR 215)
 A–122, ''Cost Principles for Non-Profit Organizations'' (2 CFR Part
230)
 A–133, ''Audits of States, Local Governments and Non-Profit
Organizations,''
 Those sections of A–50 related to audits performed under Subpart
F— Audit Requirements of this Part
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Final Invoice Preparation
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CGA Billing Team Responsibilities
 Contract & Grants Accounting (CGA) is responsible for
billing and payment processes for sponsored projects
 Key billing functions:
 Prepare timely and accurate invoices in accordance with
award documents, University and sponsor policy
 Submit invoices to sponsors
 Exception: Clinical trials invoicing initiated by departments (copy
CGA)
 Cost Reimbursable - CGA generates invoices based on
actual expenses incurred and posted to the General
Ledger up to the authorized spending limit
(appropriation)
 Exception: approved PETs, submitted / approved journals for a
final invoice or a late award set-up
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Departmental Administrator’s Role in the
Final Billing Process
 Review and ensure that all appropriate project expenses are
reflected in the General Ledger prior to termination date
 Submit any pending cost transfer requests so that they can be
received and processed prior to the award end date or activity
period end date
 Review any open requisitions, purchase orders and contact
Accounts Payables attempting to close immediately
 For subcontracts, including those with other University of California
campuses (intercampus), ensure final invoices have been submitted
and paid
 Determine if a carryover justification is required to move the
unexpended balance from one activity period to the next
 Determine if a no-cost extension (NCE) is required for the award
and submit a request for an extension prior to award or activity
period end date
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Final Invoices Continued…
 If UCSF is the subcontractor and another institution is
prime, ensure all services provided have been paid in
full
 If this is the final year, contact all recharge departments
to terminate or change chartstring for any toll charges,
phone lines and other UCSF Services such as animal
care, storage etc
 Review and remove unallowable costs per the office of
Management and Budget (OMB) Circular A-21 and
UCSF charging practices
 For additional requirements, refer to the
contract/agreement terms and conditions as well as
University policies to fully comply with regulation and
sponsor requirements for closing out an award
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Final Invoices Continued…
After the final invoice filed, clear overdraft or
deficit within 90 days of the activity period or
award end date
 Overdraft
 Represents the amount that spending exceeds the
award budget
 Deficit
 Represents the amount the total expense exceeds
total revenue
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Clinical Trial Post Award Topics
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Set Up of Clinical Trials
 Private Industry Clinical Trials
 Fund number 4400 is used
 Award purpose on award profile page is CLIN
 Award must be registered in www.clinicaltrials.gov by
UCSF
 Facilities and administration (F&A) is assessed on
gross receipts, not only an expenditure basis
 Base code is M
 The assessment is based upon a “substitution” equation 1 –
1/(1+Rate)
 The substitution rate is rounded to one decimal point
 The rate for clinical trials is negotiated at 33.0% of
total direct costs; the “substitution” rate is 24.8% of
gross receipts.
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Set Up of Clinical Trials, continued
Private Industry Clinical Trials
 The rate for off-campus clinical trials is negotiated at
26.0% of total direct costs; the “substitution” rate is
20.6% of gross receipts
 Department is responsible for sending the invoice to
the sponsor; the department must also send a copy of
all invoices to the Contracts and Grants Accounting
unit, so that the invoice can be tracked for payment in
the RAS accounts receivable module
 The appropriation is done at the time of invoicing or
time of sponsor payment, whichever comes first
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Set Up of Clinical Trials, continued
Flow-Through Clinical Trials
 Fund number 4301 is used
 Award purpose on award profile page is CLINO
 Award must be registered in www.clinicaltrials.gov
by the sponsor
 Facilities and administration (F&A) is assessed on
expenditures, not gross receipts
 Base code is either C for total direct costs or A for
modified total direct costs
 The rate for clinical trials is negotiated at 34.0% of
total direct costs or modified total direct costs
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Set Up of Clinical Trials, continued
Flow-Through Clinical Trials
 The rate for off-campus clinical trials is negotiated
at 26.0% of total direct costs or modified total
direct costs
 Department is responsible for providing
information to the Contracts and Grants
Accounting unit, so that it can create an invoice
that will be tracked for payment in the RAS
accounts receivable module
 The appropriation is done at the time of the
award activation and subsequent award
modifications
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Set Up of Clinical Trials, continued
Pending Matters
 The definition of clinical trial is going through a
review, to treat all agreements registered in
www.clinicaltrials.gov consistently
 We are reviewing whether an intercampus clinical
trial falls under CLIN and assigned to fund 4400, or
CLINO and assigned to fund 4301
 Treatment of pre-clinical administrative costs has
not been finalized by the campus Costing Policy
Group. This oncludes both start-ups costs for a
specific clinical trail, and set-up costs prior to
proposal for a specific study, such as CHR protocol.
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Set Up of Clinical Trials, continued
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Post Award Hot Topics
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Post Award Topics
 Advances
 GAEL
 RSA updates
 STIP
 Record Retention
 SAM Registration
 T32 Management
 Surplus Transfers
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Advances
 Why do we need an advance?
 Funding for a subsequent year can be delayed for a
number of reasons; an advance allows the Department to
spend on the award while the negotiation process is being
concluded
 What is the benefit of getting an advance?
 Ensures that costs can be placed on the correct
award/project in the General Ledger
 Ensures that cost transfers are minimalized and that late
cost transfers are avoided
 Documents financial responsibility should the contract not
be awarded
 Ensures that compliance concerns are addressed prior to
the initiation/continuation of work on the project
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Advance, continued
What is the process to request an advance?
 Please consult with your Research
Management Services (RMS) contact early to
ensure that the fund advance is completed and
sent to CGA in a timely manner
 The Award Advance Request Form and Award
Activity Period Advance Request can be found
on the Office of Sponsored Research website
http://osr.ucsf.edu/forms
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GAEL
 GAEL refers to the General, Automobile, and Employee
Liability (GAEL) assessment
 The GAEL assessment is tied to the distribution of payroll
expense ledgers for all regular salary lines (HRG, HST), but is
NOT an employee benefit
 The GAEL assessment posts monthly at the time that the
distribution of payroll expense subsidiary ledger is migrated to
the general ledger
 In the new chart of accounts, the account number is 57400
 In the prior chart of accounts, the expenditure NCA code is
437970
 The GAEL assessment is exempt from federal or federal flow
through funds with a 100% federal share
 On sponsored project awards, the GAEL assessment is subject to
the facilities and administration (F&A) base and rate of the
project that posts the payroll
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GAEL
 If an award is coded as a federal flow through with a 100% share
from the federal government, the award will be coded as federal
flow through code 3 in the Award Details link
 Steps to Exempt GAEL from 100% Federal Flow Through
 Secure proof that the award is 100% federal; there might be an
overlooked section of the award with a pertinent clause, or perhaps a
sponsor e-mail will attest to the 100% flow through status
 Once proof of 100% federal funding is available, send a request to the
Contracts and Grants Accounting service desk to have the award
updated and the general ledger reflect the reversal of GAEL entries to
date [email protected]
 The federal flow through code on the Award Details link will be
updated 3, and the prime sponsor agency will be added; any award
that is updated to 3 where the prime sponsor is an agency of the
Public Health Service will be subject to the federal salary cap
 Contracts and Grants Accounting will reverse the cumulative GAEL
assessment on the award with a 535 financial journal
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GAEL
SAMPLE PROOF OF 100% FEDERAL FUND FLOW
From: Hax, John [email protected] [[email protected]]
Sent: Tuesday, September 30, 2014 12:10 PM
To:
Cc:
Subject: RE: Contract #28838 (CFDA #84. 126A) Award A121902
Hi
:
100% of the funds you receive as payment on your 801B service invoices are ‘federal’ funds. Once your
match is received and the federal draw down funds are received from the federal Rehabilitation
Services Administration, all funds are to be identified as ‘federal’ funds. Hope this helps.
John R. Hax, Program Specialist
Collaborative Services Section
CA Department of Rehabilitation
(916) 558-5438
CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged
information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited
and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please
contact the sender and destroy all copies of the communication.
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GAEL
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GAEL
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GAEL
If an award is a non-federal or non-federal
flow through, and the sponsor disallows the
GAEL assessment, the department will be
required to cover the assessment
 In the case of non-federal GAEL disallowances, the
GAEL will not be reversed
Departments will be required to transfer the
cumulative GAEL accrued on account 57400,
at the project level, from the sponsored award
to a discretionary fund, using a 535 financial
journal
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STIP
The University defines STIP as a general resource
available to the department head to invest in
strategic plans as he/she best determines.
Therefore, the intradepartmental allocation of
STIP is not considered necessary, except where an
external sponsor requires the allocation of STIP to
the award
If the department head determines an
intradepartmental allocation of STIP is necessary
to meet the department's strategic objectives,
the intradepartmental allocation may not cross
fund families
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STIP, continued
When the sponsor mandates that STIP be
allocated to the award, the Department is
responsible for transferring all reportable STIP
onto the award throughout its life
Department must request budget entry through
[email protected]
CGA will monitor for compliance with the award
terms during the generation of the FSR and at the
time of closeout
Information on this policy:
 Job Aid – to come
 Contact - Denis Nepveu, Director - Resource Planning
[email protected]
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Record Retention
 A records retention schedule defines the period of time
that records should be retained and when they should
be destroyed
 Various requirements based in law and university policy
govern the retention of administrative records
 A retention schedule is critical for promoting responsible
records management, mitigating risk, and ensuring
consistent compliance across UC
 Record retention resources are as follows:
 Records Retention and Management Policy 050-19 located at
http://policies.ucsf.edu/policy/050-19
 UC Records Retention Schedule located at:
http://recordsretention.ucop.edu/
 Campus Records Management Coordinator: Brenda Gee DePeralta
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System for Award Management (SAM)
SAM, launched in 2012, integrated 8 federal
procurement systems (including the old CCR) into
a single streamlined system
Provides federal government with details of
management, performance, representations,
certifications, etc.
Registration is updated annually (next due date
3/5/15)
Awards/subcontracts may request UCSF to
provide SAM status or expiration date
https://www.sam.gov/portal/SAM/#1
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System for Award Management (SAM)
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T32 Management
 Appointments
 Appointment forms must be submitted through xTrain
before the start of the trainee’s appointment or
reappointment
 Must correlate to the trainees identified and stipend
charged to the general ledger
 Stipend levels detailed at:
http://grants.nih.gov/training/nrsa.htm
 Generally appointments are for a full-time, 12 month
period
 Termination Notices
 PD/PI is responsible for submitting, via xTrain, within 30
days of the end of period of support
 xTrain – Business Officer is Freddie Robinson
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Surplus Transfers
A surplus may result at the expiration of a
fixed priced award/activity period
Sponsor agreements may require that surplus
amounts be returned to the sponsor, or may
be retained by the University
Surplus transfers, within the University, should
be recorded on a 78% account number
 The amount transferred should consider the IDC
impact
 Any questions should be directed to the CGA
Award Closeout Team
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Compliance Update
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Compliance Update
Transition
 Initiated search for Compliance Manager
 Rick Blair will serve as interim Compliance
Manager
Key Initiatives
 Effort Reporting – period closes 10/31/14
 T32 Policy Change
 Audit Status Updates
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Effort Reporting Considerations
Roles
 ERC role is to facilitate process, organize and
communicate with PI
 PI role is to review and certify
Function – PI is certifying based on first hand
knowledge of effort
 If a PI has already certified an entire report for
another faculty member, there are two possible
solutions
 If the effort certification is correct, the faculty member
should add a comment to their effort report stating
concurrence with the certified percentages; comments may
be added after certification by using the Comments tab
 If incorrect, the report should be recertified
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T32 Award Policy Change
 The NIH Grants Policy Statement changed the allowability of Training Related
Expenses in 2014 – for this to be applicable at UCSF, we must adopt a new
charging policy and update our payroll system
http://grants.nih.gov/grants/policy/nihgps_2013/nihgps_ch11.htm#_Toc271265131
11.3.8.4 Training-Related Expenses
 Our goal is to have the new campus policy in place and the payroll system
modified by the end of the year - the final implementation date will be announced
in an upcoming newsletter
 The new campus policy will allow for the charging of
 Health benefits (medical, dental and vision) ▪ Tuition and fee
 Leave rights
▪ Travel
 Malpractice insurance - if the research training experience involves direct contact with
patients or human subjects
 The following items will continue not to be chargeable to grant:




Disability insurance
▪ Life insurance
Union dues
▪ Unemployment insurance
Workers’ Compensation
▪ FICA
GAEL (General, Auto, and Employment Liability)
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Audit Status Updates
Audit status
 Annual Financial Statement Audit
 A-133 Audit
 Compliance Reviews – Administrative Expenses
Thank you for your assistance during the audit
process and your diligence during the year
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QUESTIONS?
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We Are Here To Serve You
 Research Management Services (RMS) for federal grants,
fellowships, cooperative agreements and all non-profit sponsors
http://osr.ucsf.edu/find-my-osr-staff
 Government and Business Contracts (GBC) for federal contracts and
all state, city, county, and foreign government/organization
sponsors
http://osr.ucsf.edu/content/gbc-contact-information
 Industry Contracts Division (ICD) for all industry sponsors (industry
is the prime sponsor)
http://ita.ucsf.edu/about/staff
 CGA Service Desk for post-award issues
[email protected]
Also a CGA service quality survey at
https://ucsf.co1.qualtrics.com/SE/?SID=SV_cuSKJUDE6sZTnjT
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