GRANTS CRADLE TO GRAVE ALUMNI CENTER BALLROOM MAY

GRANTS: CRADLE TO GRAVE ALUMNI CENTER BALLROOM MAY 6, 2014 Post Award Processes & Effort Reporting Roberta Mc. Manus 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 Ø Signed by appropriate institution authority • Award is to FSU, not the PI • Proposal and Award number • Project number assigned – budget activated! ØCost sharing accounting • Research can begin Ø Adhere to scope of work Ø Collaboration/subcontracting to other individuals/institutions • Monitoring of activities - documentation Ø Status reports Ø 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 ØNew funding increment? ØRequest extension if needed/allowed ØNotify 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 ØObligations in proposal and/or award documents • 2 months of PI’s effort for academic term • 15% of PI’s time for fall semester ØMust 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 ü Avoid late cost transfers § Charges posted allowable ü Necessary and benefit the award • Subcontractor § SOW complete § Final invoice processed timely • Effort reported for amount of time expended on project • Commitments met ü Funded or not funded by award

8 Compliance Requirements • Federal ØNew Federal guidance issued December 2013 ØEffective for awards/increments issues on/after December 26, 2014 ØOMB 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 ØAgency specific requirements ØTerms and Conditions of award • Non Federal ØTerms and Conditions rule!! • FSU SR Related Policies and Procedures Øhttp: //www. research. fsu. edu/contractsgrants/policypro. html#

9 OMB Circular A-21 • SRS/SRAS use this resource daily • Allowable means: ØReasonable (prudent person) ØAllocable (relative benefits) ØTreatment is consistent (direct vs. indirect) ØConforms to limitations or exclusions (e. g. salary caps) • Direct costs Ø“identified specifically with a particular sponsored project” • Facilities & Administrative (F&A) costs Ø“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) Ø 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 ØFrequent cost transfers ØLate cost transfers ØInadequately documented or justified cost transfers • Examples of improper/unallowable cost transfers ØUtilizing unexpended funds ØMoving overrun on one project to another project ØMoving unallowable costs on one project to another project ØCircumventing award restrictions ØReimbursing a temporary “loan” of funds from another project

14 Cost Transfer Policy • Proper cost transfers ØThe transfer represents an adjustment for an erroneous charge ØSplit purchase • Timeliness ØEssential to evidence sound fiscal management ØMonthly reconciliations!!!!! • Policy ØPayroll/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 ØAssistant 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 ØDirect ØF&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 ØPersonnel ØNon-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 ØCommitted – Mandatory vs. Voluntary Committed § Must account for and report Ø“Project Enhancement” § Do not have to account for and report

19 Cost Sharing • Include in the proposal budget Ø Cost Share Commitment Form Ø Signed by Chair/Dean/Director • Cost Share budgets are set up in OMNI Ø Sponsored award/cost share budget set up same time Ø Important to get cost share info to SRA or will hold up being able to spend • Does not include 3 rd party • Transfer cash when using these funding sources: Ø PI Support projects Ø SRAD projects Ø FSU Foundation Ø 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 Ø Timing of when personnel need to be appointed Ø Timing of when supplies will be used Ø Collaboration with subcontractor in accordance with SOW • Periodic budget vs. actuals reports (OMNI) Ø Ensure anticipated expenditures charged Ø Review for expenditures that do not belong on project Ø Rate of expenditures reasonable for pace of research progress ØExpect/Request expenditure reports Ø Personnel – staff charged/encumbered Ø 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 ØPayroll cost transfers (Retroactive Distribution of Funding – RDF) ØCost Transfer Justification Form • All journal entries ØCost Transfer Justification Form • All interdepartmental requisitions ØSales between departments (stockrooms, machine time, etc. )

23 SRA Review of Expenditures • Compliance Evaluation Criteria ØAuthorized Signature • Sponsored Project Manager or PI ØChartfield Information • Dept. ID, Fund Code, Project Combination ØPerformance Period • Goods or Services received and consumed within begin/end dates of award • Available Balance ØDirect cost budget check • Budget category line item • FDP/RTC

24 SRA Review of Expenditures • Account or Job Code ØAppropriate for nature of expense • Allowable ØRemember OMB Circular A-21! ØTerms and Conditions support expense

25 Collaboration with Other Researcher • Often included in proposal ØInstitution approval vs. researcher • Participates in research (sub recipient) vs. provider of goods/services (vendor) • Starts with SRA Subcontract Coordinator • Standard agreement ØIncorporates Federal requirements • Encumbered in OMNI as PO ØNumbers = RXXXX • PI approves invoices (deliverables met)

26 OMNI Overview • Financial/Human Resource Systems • Project financial information ØJob 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 ØBudget check against direct cost budget ØExpenditures (costs incurred) ØEncumbrances (POs, T-Auths, personnel appointments) ØNot encumbered (future personnel appointments, tuition, rent, F&A)

27 PI Resources

28 Training Opportunities • CRe. ATE – Compliance and Research Administration Training and Education ØNext session Fall 2014 ØNew Federal guidance • SRA Certificate Series ØCurriculum geared toward support staff ØHands on tools ØSummer schedule in process ØSchedule 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) ØStaff Contact Information (SRAS assignments attached) ØPolicies and Procedures ØForms ØFunding Resources ØOMNI Information ØTraining Information ØEmail/Newsletter Services (recommend getting on these list serves)

30 Web Resources • Controller’s Office (http: //www. vpfa. fsu. edu/control/) ØGeneral Accounting ØPayroll Services ØProperty Accounting ØAccounts Payable ØTravel • Office of Graduate Studies (http: //gradstudies. fsu. edu/) ØMatriculation 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