Sponsored Programs at Penn
Post Award
Primer and Terminology,
Management, Closeouts and Audits
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
1
Federal Terms and Conditions
• Basic Provisions
• Supplemental Set of Federal Agency T&C
• If Federal Terms & Conditions apply( with
some agency exceptions)
– Rebudgeting between most direct cost categories
and between direct and indirect costs;
– Carry-forward of unexpended balances to
subsequent non-competitive funding periods;
– Pre-Award costs for up to 90 days prior to the
effective date of the award
– Time extensions (one-time only), without additional
funds, for up to twelve months;
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
2
Carryover Authority & SNAP
• Carryover Authority
– Generally R’s, K’s and P01’s, but always
check the Notice of Grant Award.
• SNAP
Streamlined Non-competing Award Process
– Generally R’s, K’s
– A grant must have carryover authority if it
is under SNAP
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
3
Remember!
• At Penn, grants with automatic carryover retain
same fund # for the entire segment.
– An exception to this rule is subcontracts.
• All grants without automatic carryover receive a
new fund # every new budget period.
Understanding this most basic concept helps you
understand when a fund # should expire, require a
closeout, or when an advance account may be needed
as the project continues.
IT IS VITAL TO UNDERSTAND THIS!!!!
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
4
Basic Terms to Know
• Revenue
Recognition
• PBIL and PBUD
• FSRD and FSRI
• Operating Budget
• Object Code 1220
Receivable
• Adjustment Period
• MTDC
• Encumbrance/Unliquid
ated Obligation
• Unobligated Balance
• Letter of Credit
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
5
Revenue Recognition
Revenue
• Our entitlement to be reimbursed by the
sponsor for the allowable expenditures of the
grant
• An equal $ of Revenue is recognized for every
$ of allowable expense in object code 4600
Grant Revenue
• Unallowable expenses and expenses above the
award amount do not recognize revenue
• Revenue does not necessarily reflect the cash
received from the sponsor
WHAT’S WRONG WITH CHARGING AN
INDIRECT COST
DIRECTLY TO THE GRANT ?
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
6
Other Potential Sources of
Revenue on a Grant Fund
• University Funded Cost Sharing
– Obj. Code 4822 – Mandatory or Voluntary Committed
– Obj. Code 4827 – Overrun/Uncommitted
• TIF (Interest) Income - Object Code 4780
• Program Income - Object Code 4620
In the end
(at closeout and disablement of the fund),
all sources of Revenue must equal Total Expense.
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
7
Grant Receivables
• As invoices are submitted our billed A/R (o/c
1220) reflects invoiced amount billed
• As costs are expended with no associated
billing generated, our Unbilled A/R (o/c 1222)
goes up
• Our deferred revenue (o/c 2630) reflects the
amount of cash on hand
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
8
Grant Receivables
(Object Code 1220)
LOC
Letter of Credit funds have a zero
receivable. The actual receivable
resides in a special holding fund
for all funds under the specific
LOC.
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
9
Special Object Codes
(entered by Research Services)
PBIL - The Maximum Billable Award
PBUD - Authorized Project Budget
FSRD - The Total Direct Costs reported to the
sponsor
FSRI - The Total Indirect Costs reported to the
sponsor
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
10
More on PBIL
PBIL/Billable
• Serves as the control and limits
revenue recognition up to award
amount
• Gets reduced to reported amount and
guarantees that revenue recognition
above reported amount does not occur
• Will always be rounded to nearest
dollar. Cents will only show if there has
been a carryover of funding from a
previous fund (increase) or has been
adjusted to the reported amount
(decrease)
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
11
More on PBUD
PBUD
Most often equal to PBIL except on
advance accounts
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
12
Operating Budget
REVISED May, 2015
(Entered by Administrator)
The Office of Research Services
The Office of Research Support Services
13
Unliquidated Obligations/
Unobligated Balance
• Unliquidated Obligations
– Commitments of the budget period not yet
paid
– When reported funding gets reserved in the
next budget period so they can be paid
– Must liquidate within 90 days (UG)
– Can not be reported in the final period
• Unobligated Balance
– unspent and uncommitted
– may be able to carryover automatically or
with approval
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
14
Project Management
Agenda
• Communication
• Establishing the Project Environment
• Managing Monthly
• Monitor Expenditures
• Cost Transfers
• Cash Management
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
15
Communication
• Report monthly to PI
– Establish payroll distribution
• Establish level of effort anticipated for each individual on
project – Be mindful of Salary cap limitations
– Restrictions on spending
• Special Terms and Conditions within Award Notice
– Monitor Subcontracts = Confirm amounts & work done
• Review each invoice (SPP #2131, #2135 Sub-recipient Monitoring
policies)
• Communicate regularly with ORS
–
–
–
–
Extensions / Continuations and other project changes
Financial reports, delinquent sponsor payment
Inform Sponsor via ORS of any Programmatic changes
Assesses allowability of costs
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
16
Establishing the Project Environment
Payroll Set-up
• Identify who belongs on distribution
• Identify amount of funding and % effort
• Distribution Stop Date s/b set to the
Account End Date
• Salary Encumbrances are calculated
through the Current Budget End Date or
Distribution Stop Date (whichever is
earlier)
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
17
Support the Project
• Work with PI on on-going basis
• Ensure that interim reports &
proposals are submitted on time
• Disclose Inventions and Patents
• Prepare for Progress Reports and
Non-Competing Continuations
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
18
Procurement
• Ben Buys Commodity Matrix
– Methods of Purchasing
– When should C-1, C-1A, C368,
Purchase Order, or P-Card be used
• http://www.purchasing.upenn.edu/buyinfo/matrix.php
• Competitive Bids
Required on aggregate purchases >
$5,000 unless purchase is with a
University Contract Supplier or with a
supplier participating in the Penn
Marketplace. (UG-May change to $3000)
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
19
Cost Share
• Types of Cost Share
– Mandatory – costs required by terms of award that the University must
contribute toward project in order for award to be made.
– Voluntary Committed – costs associated with project (identified in proposal
or budget justification) for which funding has not been requested from
sponsor.
– Voluntary Uncommitted – costs associated with project NOT identified
within proposal or budget justification and NOT funded by sponsor.
– In-Kind / Matching - Refers to funds being matched in some proportion with
non-sponsored project funds, or that the grantee participate to some extent
in the cost of the project. Matching requirements may be in the form of an
actual cash expenditure of funds, or may be an “in-kind” match, which is
the value of non-cash contributions to the project.
• Tracking Cost Share Commitments
– Costs must be expended as proposed and recorded throughout life of
project (separate fund ?)
– Same allowability rules apply & same performance period as primary award
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
20
Program Income
• Definition
– Gross income earned that is directly generated by a sponsored activity or
earned as a result of the sponsored activity
• Some examples: Income from fees or services performed from external entities or
within University, Revenue from sale of tissue harvested from project.
• Methods of Program Income
– Additive = income is added to sponsor commitment.
– Deductive = income used to reduce sponsor commitment.
– Matching = income used to finance portion of departmental commitment.
• Tracking Program Income
– Program income rec’d from external entities must be deposited into o/c
4620
– Revenue earned by University dept for fees or selling goods or services to
another Univ. dept is consider internal revenue and must be recorded using
o/c 5500.
– Program Income fund is to be set-up to account separately for the costs of
collecting and spending the Program Income Awards in which Gross
Program income may be off-set by the costs of collecting the income to
enable reporting Net Program Income.
($5,000 threshold)
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
21
Equipment
• Definition – tangible, nonexpendable, personal property having a
useful life of more than one year and an acquisition cost of
$5,000 or more per unit
• Must be necessary for project purposes
– During the award period
•
•
•
•
Is not reasonably available for use elsewhere in the University
Award notice does not constrain equipment purchases
Must obtain necessary bids, unless sole source justification
Document whether Equipment is
– Government owned
– Government furnished
•
Disposition after the project has ended
– Know sponsor regulations
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
22
Computing Devices & the UG
• Computing devices are defined in the Uniform Guidance, 2 CFR
§200.20 and 2 CFR §200.94:
• Computing devices means machines used to acquire, store,
analyze, process, and publish data and other information
electronically, including accessories (or "peripherals") for
printing, transmitting and receiving, or storing electronic
information.
• A computing device is a supply if the acquisition cost is less
than $5,000, regardless of the length of its useful life.
• The UG States: In the specific case of computing devices,
charging as direct costs is allowable for devices that are
essential and allocable, but not solely dedicated, to the
performance of a Federal award.
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
23
Computing Devices cont’d
• The following criteria will be used to determine
essential & allocable:
– The need has been included in original proposal and
completely justified
– Device is necessary for the performance of the project
– Project will be negatively impacted by not purchasing the
computer or electronic device
– Costs are reasonable and directly benefit the project that
purchases the device
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
24
Consultants
• Evaluate: Consultant, Employee or Subcontractor?
– Use C-12 Independent Contractor Determination &
Certification
http://www.finance.upenn.edu/comptroller/tax/contractor_
certif.shtml
• Consulting agreement needs to be completed and
forwarded to ORS for approval & signature
• Document role of consultant
– Needs to be working towards goals of project to which he/she is
charged
• Review sponsor guidelines for consultants
– Ensure approvals are obtained, if applicable
– Consultant rates may be limited for some sponsors
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
25
Purchases
• PI approval process for purchases
• Assess allowability, allocability and
reasonableness
• Verify budget and availability of funds
• Procure bids
• “Buy American” on federal awards when possible
• Don’t buy capital equipment at end of project
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
26
Service Centers
• Definition:
– A department or functional unit within a department,
which performs specific service for a fee
–
Examples: Cell Sorting facilities, Resonance Imaging
facilities, and Animal Care facilities
• ORS responsible for review & approval of rates
– Services provided charged based actual use of services
– Charges for services allocated monthly
-Financial Policy #2115 University Service Centers
• Make sure Service Centers use correct fund account
• PI & BA should review Service Center charges regularly
– The BA may not know what services were provided, or if
the amount charged is appropriate
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
27
Manage Monthly
• Plan expenditures in advance
– This will make the project easier to manage throughout life
of project
• Run and analyze appropriate reports
•
•
•
•
– Financial Policy #1402.5 Monthly Closings/Reporting
Send detailed reports to PI
Remove unallowable and wayward charges
Compare expenditures to projections
Manage changes through full system
– Changes in award value affect payroll
– Changes in subcontracts or equipment affect F&A charges
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
28
Manage Project Changes
Proactively
• Use proposal as “home base”
• Anticipate necessary changes
– Contact ORS for approval
– Get sponsor approval through ORS
– Change of scope or effort
• Plan ahead for extensions
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
29
Monitor Expenditure Rates
• Sponsors question unusual expenditure
rates
• Have we changed scope of work?
• Are we still breathing?
• Communicate with Sponsor (cc ORS)
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
30
Cost Transfers
• The transfer of costs to sponsored projects
where the costs initially had been incorrectly
charged to another account. Any cost transfers
that occur need to be properly justified and
documented.
• University Financial Policy Number 2113 Cost Transfers and
Payroll Reallocations states "Cost transfers must be prepared
and submitted within 90 days from month end in which the
transaction appears on the fund." Failure to adhere to this
policy may result in the University disallowing the transfer
which would result in a write-off to the administering
department.
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
31
Cost Transfers
• Must be an allocable, allowable
and justified charge to the
particular award
• Department must maintain
documented justification for transfer,
regardless of <or> 90 days
• Must be made within time constraints
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
32
BEN Cost Transfer J/E
Categories
• BEN Financials Journal Entry Responsibility titled Journal
Entry – G&C Costs Transfers
– Improve monitoring, tracking and compliance with the University’s cost
transfer Financial Policy # 2113.
• BEN Financials Journal Entry Responsibility for UPHS
transfers
– 17 UPHS Gds/Svs
– 18 UPHS Payroll
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
33
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
34
Cost Transfer Principles
• Cost transfers are for correcting legitimate
ERRORS
• Cost transfers should NOT be used as a means of
managing cash flow
• Project funds are NOT interchangeable
– Integrity of each grant account must be maintained
• Allowability of costs must be maintained
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
35
Cost Transfers
• Documentation
– Supported by full explanation and
justification, as well as a certification of the
propriety of the transfer
– Explanations such as “to correct error” or
“to transfer to correct project” are not
sufficient
– Approval can be documented by
• PI signature
• Printed e-mail messages from PI
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
36
Cost Transfer “Red Flags”
• Transfers made in excess of 90 days after the original
charge
• Improper J/E Categories (15 G&C UN90, 16 G&C OV90)
• Transfers without a full explanation
• High volume of transfers
• Timing and “route” of transfers
• Late transfers to funds with unexpended funds
• Transfers from funds with overdrafts to other 5 fund(s)
• Transfers between funds with scientific overlap
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
37
Advance Accounts for
Continuation Awards
• Recommended for non-competing renewals
requiring new fund #’s for each period
– Department requesting the advance account bears the
risk of having to fund any costs incurred if the funding
never materializes
– Med School sets up NIH advances for full budget period
– All other Schools set up Advances for 3 month period
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
38
Monitoring Accounts Receivable
• For Letter of Credit awards, check revenue & cash
received.
• On Letter of Credit, confirm that PBIL is correct
• Contact ORS to address payment problems with
sponsors
– Departments should review AR and contact ORS regarding
aged receivables of concern
• For awards on payment schedule, contact Jen Rowan
• For all other awards, contact Gokila Venkateswaran
• For Med School awards, ORSS representative is Danielle DiIanni
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
39
Checks, Payments and Project
Budget Increases
• Hand carry check to ORS immediately, with
project identification
– Do not deposit check
• Should AIS be increased because of check?
• What is GCINVOICING-L@lists.upenn.edu ?
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
40
Run and Review Reports
• BEN Reports
–
–
–
–
102.ORG
115.ORG
133.ORG
134.ORG
–
–
–
–
Summary CNAC-ORG-FUND level
Fund Summary
Due to Close
Summary of Final Expenditure Report
• Data Warehouse
– Fund Summary (with date range)
– Org Summary & GrantMonitor
– Corporate Documents
• Payroll
• Correct Errors
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
41
Management of All Grants in ORG
BUSINESS OBJECTS
ORG Summary
by Fund, PI, Acct End, receivables, overdrafts, funds
freezing, late/due FSR’s, Analysis of expired funds, Illegal
object code charges, possible F&A direct charged to Fed grants,
payroll compared to budget.
Grantmonitor
PBIL/PBUD/Budget, NCC Due, Awards Due, Revenue
Check, Overdrafts (active and expired), Federal Cash, CT Cash,
Residual Balances, Receivables
Subbudgets our charges to others
Otherorgschgs
ORG Wayward Summary.rep
ORGpersonnel. all current distributions of home dept org
Award Analysis- Award Date
PT-Requests (all proposals submitted for any time period)
JE inquiry (by batch between dates)
FY Grant ORG Expense Analysis
Effort Report – Home Dept ORG
Object code by fund – posted org
Object code by fund – detail
REVISED May, 2015
AIS (full search)
Protocols – Org/ Protocols – PI
BEN FINANCIALS
132.ORG List of Terminated G&C Funds
133.ORG List of G&C Funds Due to Close
138.ORG Frozen Fund List
201.SCH PJTD Rev/Exp for G&C/URF
202.SCH YTD Rev/Exp Totals for Funds
211.SCH PJTD Rev/Exp Outline for G&C/URF
212.SCH YTD Rev/Exp Outline for G&C/URF
301.BUD Budgetable Amount - Grants/Contracts
306.BUD Negative BBA ORG/FUND/CREF PJTD
The Office of Research Services
The Office of Research Support Services
42
Fund Level Management
BUSINESS OBJECTS
BEN FINANCIALS
fundsummary
fundsummary (w date range)
summary by ORG/CNAC
SNAP/NCC estimated unobligated balance
Effort calculations
Fund Detail
monthly matrix all expense
monthly matrix personnel paid
102.ORG Summary G&C by CNAC/ORG/FUND
103.ORG Summary G&C by CNAC/ORG/FUND/CREF
115.ORG Grant Fund Summary Report
130.ORG PI Report by CNAC/ORG/FUND
134.ORG Summary of Final Expenditure Report
(available for grants in adjustment period)
137.ORG Grant/Contract Budget Period Summary
FUNDpersonnel – all current distributions on fund
Effort Report – Fund
GRANT REPORTS (-Resp Org, -PI, -CREF, -PI Awarded)
PI friendly & monthly payroll and expense detail
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
43
Expense Detail
BUSINESS OBJECTS
Fund Detail.
Payroll by Obj, by Person,Exp Detail by Object, Org, Acct
Period, P.O./User
Fund Detail – PI
monthly matrix of personnel paid on PI grants
Payroll.(any fund any period of time)
variations include:
All grants of PI
All grants of Resp Org
Personnel.(any person, any period)
Personnel-one (any person’s current distrib)
Detail.
variations include:
All grants of PI
All grants of Resp ORG
subcontracts
object
special budget
operating budget
REVISED May, 2015
cash deposits
Encumbrances(Fund)
ORG Wayward Detail
BEN FINANCIALS
150.ORG Detail by CNAC/ORG/FUND
151.ORG Detail by CNAC/ORG/FUND/CREF
152.ORG Detail by CNAC/ORG/CREF
153.ORG Detail by CNAC/ORG/FUND/PROG
155.ORG Detail Extract
156.ORG Detail by CNAC/ORG/FUND/PROG/CREF
160.ORG Account Analysis with payables detail
163.ORG Open Encumbrances Report
301.BUD Budgetable Amount - Grants/Contracts
304.BUD Negative BBA ORG/FUND YTD
305.BUD Negative BBA ORG/FUND/CREF YTD
306.BUD Negative BBA ORG/FUND/CREF PJTD
315.BUD Posted Budget Journal with Exceptions
507.GA Posted Journal Activity Report
508.GA Unposted Journal Activity Report
510.GA Detail Transaction by OBJECT by ORG
The Office of Research Services
The Office of Research Support Services
44
Your assignment
• Full documentation of the Business
Objects Queries is available at:
http://www.upenn.edu/computing/da/dw
/financial_queries.html
Select “Grants Management”
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
45
In Summary
• Award must be reviewed on a
regular basis
• Communication is vital to the
proper administration of the award
• When you are not sure, investigate
and ask
• If an award is properly managed,
the closeout process is very simple
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
46
Sponsored Programs at Penn
Closeouts and Audits of
Sponsored Project Funds
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
47
Closeout of Sponsored Project Funds
Agenda
• PI & Department responsibilities
–
–
–
–
–
Communication
Pre-closeout review
Adjustment period
Freeze/unfreeze grants
Technical & invention reports
• ORS responsibilities
– Unfreeze requests
– Financial & non-financial reports
– Disabling accounts
SPP # 2126 Interim & Final Financial Reports
SPP # 2128 Account Close-out
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
48
What is the Adjustment Period?
• Period of up to 60 days after Account end
date
– Allows for final review of project activity
so adjustments can be made prior to final
reporting
• 30/31 days:
• 45 days:
• 60/61 days:
• 90/91 days:
Account
Account
Account
Account
End
End
End
End
Date + 15 days
+ 30 days
+ 30 days
Date + 60 days
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
49
Adjustment Period (cont.)
• Run 134.ORG Report in BEN Financials
or Fund Summary in Business Objects
– Review the following areas
• PBUD/PBIL should be equal
• Revenue vs. Expense
– Should be equal
– If not, requires further review
– F&A and Employee Benefits (EB) – Were
the correct rates appropriately applied?
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
50
Adjustment Period (cont.)
– Review the following areas (cont.)
• Payroll – Any adjustments that may be
needed must be made by the end of the
adjustment period
• Service Centers – Were these handled
appropriately
• Cost transfers over 90 days that were
done without prior approval
• Other direct costs for allowability
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
51
Final Review Prior to End of Adjustment
Period
• Review PBIL/PBUD, NOGA and approved carryforward,
if applicable
• Review subcontracts and respective closeouts
• Communicate with ORS Accountant
– Outstanding reporting/receivable issues
• Determine and address
– Unliquidated and unobligated carryovers
• All adjustments must be processed by end of the
fund adjustment period
– Complete all approved, allowable, allocable and
appropriate adjustments identified during precloseout review
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
52
Best Practices for
Communications
• Emails - the subject line of your email should be
informative
– “Action Fund#, P.I., Description
– Examples:
• “Closeout 538500, Mendel, 5K23MH024680-03”
• “Unfreeze 538000, Frankenstein, 5R01HG012345-05
• One email per fund action
• Email ORS Accountant and notify them of the
Direct, Indirect, Total Expenses and provide any
closeout detail documentation needed by the end
of the fund adjustment period.
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
53
Freeze/Unfreeze Grant
Functionality
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
54
Freeze Grants Functionality
• Tool that allows authorized research
administrators and ORS to limit activity
against an award
– Can be used during life of project and
during the adjustment period
– Can reduce cost transfers and overruns
after the end of the fund project period
– Improve timeliness and accuracy of final
financial reports
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
55
Freeze Grants Features
• Awards are frozen/unfrozen at fund level
– Payroll can be frozen manually prior to the Account End
Date
– Functionality frozen automatically after Account End
Date
• New Purchase Orders/Requisitions
– Functionalities frozen automatically after Adjustment
Period End Date (APED)
• Manual Journal Entries
• C-forms
• Feeder Journal Entries
• Payroll
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
56
Unfreeze Request (cont.)
• Are not necessary to:
– Prepare budget journals
– Pay already encumbered amounts on
an existing P.O.
– Unfreeze advance accounts (request
an extension of advance account)
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
57
Unfreeze Grants (cont.)
• Submit your request to:
– School of Medicine departments
• Send worksheet and details (including documentation)
to Office of Research Services Support (ORSS) Grant
Manager with a cc to ORS Accountant
• ORSS will review and, if approved, will forward to
Research Services Accountant and cc Assistant Director
– All other Schools
• Send worksheet and details to ORS Accountant and cc
Assistant Director
– Unfreeze requests are normally addressed within two
business days
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
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ORS Responsibilities
REVISED May, 2015
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ORS Reporting Period Tasks
• Reviews Due Reports to determine report due date
• Email will be sent requesting closeout information
• ORS Accountant reviews the following;
-Terms and conditions of award and sponsor
reporting requirements
– Review the 734 report in Business Objects
(similar to 134.ORG report in Ben Financials)
– Check PBUD/PBIL for accuracy
– Reconcile EB’s, F&A and Cash
– Review 252 report for stale dated checks
REVISED May, 2015
The Office of Research Services
The Office of Research Support Services
60
ORS Reporting Period Tasks (cont.)
• Review expenses posted to the fund for
allowability
– Revenue
• 4600, 4620, 4630, 478X, 4822, 4827, TIF, Program
Income & Other Revenue
• Review remaining balances or deficits
• ORS will communicate any issues identified and
request a response from the BA
• If the ORS Accountant does not receive a
response regarding closeout the report will be
issued and an email will be sent stating what was
reported to the sponsor.
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ORS Reporting Period Tasks
(cont.)
• Overdrafts
– ORS will contact department regarding
resolution
– If no response is received by report due date,
fund will be reported up to award amount and
ORS will process journal to transfer resources
from departmental fund to grant fund to offset
overdraft via object code 4827
SPP # 2129 Chargeback of Overdrafts and
Disallowances
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ORS Reporting Period Tasks
(cont.)
• Unexpended Balance
– Will be reported to sponsor
– Carryover will be processed and/or requested as
appropriate
– Residual cash will be remitted to sponsor according
to agreement
– Carryovers and/or unliquidated obligations will be
determined and handled as appropriate
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ORS Reporting Period Tasks
(cont.)
• Final Financial Status Report (FFR)
Submission
– Financial report will be issued by ORS no later
than due date
– A copy will be sent to department and a copy will
be scanned into our imaging system (Acorde)
– ORS will process any closing entries based upon
final reports
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Revised FFR’s
• Only done in rare circumstances
• When revising to increase total expenses, most
sponsors will only accept revised reports for
limited period of time following the end of the
award. Some agencies will not accept upward
revised FFRs.
• When revising to decrease total expenses, there
is no time limit. These should be completed
immediately upon identification of the need for a
revised FFR.
SPP # 2137 Revised Final Financial Reports
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Disabling Funds
• How does a fund get Disabled?
– ORS runs 717.RA report in BEN
Financial weekly
• To identify funds that meet disable
requirements
– If the fund is eligible for disabling
ORS checks “Enable” flag
• Enters date in BEN Financials
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Requirements to Disable Funds
1.
2.
3.
4.
5.
6.
7.
8.
Financial Report must be submitted if requiredLast FIN Report Filed=Next FIN Report Due
FSRD and FSRI s/b posted reflecting Direct and
Indirect Costs reported
PBIL=PBUD=FSRD+FSRI=Total Expenses reported
and on the G/L
No Encumbrances can remain
Object Code 1220 Receivable must =0
Equipment in Object Code 183X/187X must be
transferred to School Surrogate Accounts via an
Object Code 4826 Equipment Transfer
GMS (ORS billing system) is reconciled (requires
ORS action)
All stale dated checks have been satisfactorily
addressed
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Miscellaneous - Cost Sharing
• Cost Sharing
– How is it recorded in our system?
• Must be separately accounted - a 5 fund must be
established if Cost Share > $10K
– What needs to be done at closeout?
• Mandated cost sharing must be reported to the
sponsor
• How is it managed?
• Expenses should be recorded and monitored on a
timely basis
• Revenue entries must be routinely performed
SPP #2119
Cost
REVISED May,
2015 Sharing/Matching Requirements
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Miscellaneous – Interest
Bearing Funds
• Interest Bearing Funds
– When does an award fund receive interest?
• Monthly basis
– How do I know if my fund is interest
bearing?
• T&C of award determine
– Can I spend these funds?
• T&C of award determine
– At Closeout, what happens to these funds?
• T&C of award determine
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Miscellaneous – Program
Income
• Program Income
– What is Program Income?
• Gross income earned & directly attributable to the
sponsored activity
– How is Program Income handled?
• Additive vs. Deductive
– How is Program Income handled at
closeout?
SPP #2121 Accounting for Program Income
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Miscellaneous –
Record Retention
• What do I need to
retain?
• How long do I
need to keep it?
• SPP #2132 Record
Retention
REVISED May, 2015
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Miscellaneous –
Award Transfers
• If a PI is planning to leave the University, ORS staff
should be contacted as soon as possible to expedite the
process
• “Statement of Relinquishment” or similar document
– Required information must be verified
– ORS signature must be obtained
– Estimated unobligated balance-funds awarded on NOGA for
current year only exclusive of any amounts carried over
– Not finalizing costs may delay transfer of funds to the next
University
– Any property being transferred must be addressed
REVISED May, 2015
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Non-Financial Close Out
Issues
• Final technical and/or progress
report
• Final invention statement
• Final property report
REVISED May, 2015
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Getting Assistance on
Closeouts
• For financial matters:
– Contact ORS accountant or PostAward Assistant Director
• Regarding extensions, requests for
budget or other modifications to
agreement, or non-financial
matters:
– Contact your Contract Administrator
REVISED May, 2015
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Questions???
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Sponsored Programs at Penn
Audits
REVISED May, 2015
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Pre-Award Audits
• Performed by agency to verify
– Accuracy of costs on application
– Adequacy of University systems and
controls
• Usually performed by or at the
request of the sponsor
• Federal Awards
– DHHS is Cognizant Agency
– Sponsoring Agency
REVISED May, 2015
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Agency or Programmatic Audits
• Performed on Active or Terminated
awards
• Federal Awards normally a result of
a request by the Sponsor
– Review by Dept of Health & Human
Services (DHHS)
– Foundations and Associations
– Other
REVISED May, 2015
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Investigative/Criminal Audits
• Usually based on allegations of fraud
– Misuse of funds on awards including:
• Purchasing Card charges
• Petty Cash abuses
– Audit of how we comply with regulations
– If Federal OIG audit
• Subpoena powers
REVISED May, 2015
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Internal Audits
• University audits projects to
– Evaluate system controls
– Assess compliance with University and
sponsor policies and applicable OMB
circulars
– Investigate reports of fraud
REVISED May, 2015
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Compliance Audits
• Assess compliance with
– Sponsor regulations
– University policies
• Human Subject/Animal issues
REVISED May, 2015
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F&A Cost Proposal Audits
• Audit occurs cyclically
– During the F&A negotiation process
• F&A recovery rates are affected by
expenditures
• Interviews of PI and BA to determine
basis for assigning space to research
– Space drives the rate
– 32.5 points of 57% rate
REVISED May, 2015
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OMB Requirement for Audits
• Required annual audit of federal grants &
contracts
• Performed by independent auditors
– Penn: PricewaterhouseCoopers (PwC)
• Audit of systems and transactions
• Cost Transfers, Effort Reports, Subcontracts, Service
Centers, Technical & Financial Reports
REVISED May, 2015
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General Principles for Audits
• Good award management is the key
to good (uneventful) audits
• Good documentation is essential in
– Department and ORS
• Audits are everyone’s responsibility
– PI, BA, School, Pre and Post-award in
ORS
– Don’t go in alone
REVISED May, 2015
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General Principles for Audits (cont.)
• Audited on compliance with all
applicable regulations & policies
– Federal
– State
– Sponsor
– Specific award terms
– University
REVISED May, 2015
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General Principles for Audits (cont.)
• Audited on consistency of policy
application
• Audits may provide feedback for
process improvement
• Audit results can be expensive
• ORS & PI have a responsibility to
educate the auditor about the purposes
of the project
REVISED May, 2015
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Preparing for Audits
• Notify ORS as soon as you learn of audit
– SPP #2130 External Audits
• ORS & PI/BA meet to prepare for audit
– Anticipate questions
– Develop procedures for working with auditors
• File management
• Prepare and support the PI
– Work to prevent adversarial relationship
• Don’t panic
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Audit Lessons Learned
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Critical Audit Concerns
• Salary Charges on Awards
– Effort on award must equal or exceed
salary charged
– Effort must be documented in
Personnel Activity Report form
– Payroll Reallocations
• Same as Cost Transfers
– Communicate with PI
REVISED May, 2015
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Critical Audit Concerns (cont.)
• Cost Transfers
–
–
–
–
–
–
–
Auditors view them as corrections of errors
Explain why the error occurred
Establish correlation of charge to next grant
Provide documentation of PI approval
Maintain documentation for expense in file
Cost Transfers must be prompt and justified
“Parking” a charge is illegal
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Critical Audit Concerns (cont.)
• Documentation
– Costs that deviate from the proposal must
be justified in terms of the project
– Maintain all approvals from sponsor
– Explain why decisions were made
– PI must approve costs incurred on award
REVISED May, 2015
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Critical Audit Concerns (cont.)
• Consultants
– Document relationship with consultants
• Do not circumvent IRS employee regulations
• Do not engage an employee of sponsor or Penn
employee as a consultant
– Consulting agreement (work for hire) must
document scope of work, rate and payment
terms
• Proper inventory of equipment
– Tag & document transfer, move or disposal
REVISED May, 2015
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Critical Audit Concerns (cont.)
• Service Centers are reviewed (A-133 & F&A
proposal)
– Surpluses are problematic
• Are federal awards being overcharged?
– Rates must be adjusted to off-set the surplus
– At least annually adjust to compensate for
surplus or deficit
– Maintain documentation of charges
– Maintain records of rate determination
SPP #2115 University Service Centers
REVISED May, 2015
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Critical Audit Concerns (cont.)
• Subcontracts
– PI must monitor subrecipient performance
and expenses
• Address contract performance and payment
issues promptly
– Subrecipient must verify that it is not
debarred or suspended
– ORS monitors subrecipient audit reports
• If findings result from expenditures of
subcontract, Penn department is
responsible for the cost of findings.
REVISED May, 2015
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Critical Audit Concerns (cont.)
• Close-Out
– Penn must submit all required reports
• Programmatic, Financial, Patent, Property
– Timeliness of reports
REVISED May, 2015
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If you are contacted by a
sponsor regarding an audit…
…Contact ORS Executive
Director
REVISED May, 2015
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Questions???
REVISED May, 2015
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Sponsored Programs at Penn
Resources
REVISED May, 2015
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ORS Website and Resource Tour
• http://www.upenn.edu/researchservices/
– Homepage
– Left Quick Links
– Sponsored Projects Manual
– Sponsor Links
– Spotlights
– ORS Newsletters and listserv
– Brown Bags and other Training
Opportunities
REVISED May, 2015
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