Justifications Why are justifications needed WU is required

Justifications Why are justifications needed? WU is required by federal policies to monitor purchases. They should be q allocable (benefit the project), q allowable (per institutional and federal guidelines) and q consistently treated (within WU).

O More justification is required for federal grants than foundations or for internal funding O SPA is familiar with lab research, but not necessarily human studies research O Pediatrics has more strict internal procedures for certain purchases O New policies will be disseminated and posted soon O How items are classified (budget-object codes) tells accounting how much review and justification is required. Some typical items that require more review/justification are: O O O O General Supplies Entertainment Services Social Purchases Sponsored Project Events Equipment over $5 K Electronic Devices Purchases at the end of the grant period

O Justifications are written on check request forms or in the comments section of Marketplace orders O Some items require a special approval by SPA via an ACE (Administrative Cost Exception) form. This form is to show the unique and unlike circumstances of the award to pay for items such as: O Admin/Clerical Salaries O Research Office Supplies O Laser Printer Supplies O Postage O Local Telephone/Cell Phones O Data Lines O Memberships/Subscriptions O Some items will never be approved, no matter how well justified they are, based on standard allowability guidelines set in place by WU or the federal government

Each purchase should be items/services needed to benefit the aims presented in the research. O Items presented in the budget are not automatically approved and allowable O Justifications need to be entered for each purchase. O Each purchase (CR/PO/TR, etc) needs to be able to be viewed as a stand-alone document for auditing purposes. It cannot refer back to another purchase. O Consistent unique circumstances need to be identified and standard approved language can be worked out with SPA by administration.

A justification is an explanation of the reasons why the grant should pay for this product/service. q How does this support the aims of the project? q What value does this item provide to the science? q Where will the services be performed? q Why is this item beneficial to the science?

Helpful hints: O Blind them with science! O Do not purchase items before submission to accounting. They might not be approved! O Often the budget justification from your submission has the info needed. O Work with your administrator if you’re not sure how to handle/answer. We can advise!

Gift Cards Introduction O Currently, we have two methods for procuring gift cards to use as study reimbursements: O The TA/TR method (Travel Advance/Travel Report) O The Marketplace method

Forms and Their Purpose O TA - Travel Advance O TR - Travel Report O PO - Purchase order via Marketplace

TA (Travel Advance) O Designed to put funds in your personal account for use O O O when traveling for WU business The purpose has been altered to put funds in your personal account for use in purchasing gift cards, etc. for participant incentives The amount requested for incentives should be for approximately one month’s worth Time frame O Funds are deposited within a few days to the employee’s personal account This method is good for tracking incentives for accounting This method puts the responsibility on the individual to purchase the incentives

TR (Travel Report) O This form is completed when all patient incentives have been distributed and reconciles (closes) the open Travel Advance

PO (Purchase Order) via Marketplace O Coordinator can place a Marketplace order with various companies to request gift cards O Typically, a form from the company must be completed to show the specific incentives needed. O This form will accompany the check cut by WU to the company O Once the check is received (and cleared) by the company, they will send the gift cards O This method can take up to two or three weeks from start to finish O Time frame can be extended if vendor does not have the specific requested cards in stock O This method requires no fiscal purchase responsibility for the individual O This method requires forecasting and planning in order to not run out of incentives

New Gift Card Process 1. 2. 3. Tracking gift card purchases Sending proper information to the Tax Dept. New audit process (to comply with new policy)

Purpose of the new policy O To document proper management of patient incentives and ensure the proper handling and distribution for purposes of subject reimbursement. O This includes providing segregation of duties, documenting all payment, and ensuring proper reconciliation.

Procedures for Logging Gift Cards for Study Participation O O O 1. Coordinators will record all required information on the “Log of Payment by Cash or Gift Card for Study Participation” (Excel log attached). Other forms for reporting this information will not be accepted. There should only be 1 document number (TA/PO#) per log. 2. Once all cash/gift cards per TA/PO are distributed, send the completed log to Linda_Kennedy@wustl. edu in the tax department and CC your PA (purchasing assistant). 3. Because the form contains sensitive personal data the log MUST be password protected when sending the log to the tax department. Use password “Pediatrics” every time you send a spreadsheet. 4. Email the log to the tax department within 15 days after all gift cards/cash purchased on a TA/PO have been distributed. In the event that all gift cards/cash haven’t been distributed by December 31, provide the tax department with the current log through December 31 and start a new log for the calendar year beginning January 1. 5. Start a new log for each TA or PO upon sending a log to the tax department. 6. The tax department considers all patient incentives (gift cards, meal tickets, toys or other items) as cash. Under IRS procedures WU is required to request the SSN for all participants that receive more than $10 in the aggregate for a calendar year as compensation for participation in a research study. 7. In the event that a participant refuses to provide a SSN, enter “REFUSE” in the SSN box. Enter “FOREIGN” if the participant is a foreign national and does not have a SSN. 8. A receipt signed by the participant and the distributor should be obtained for each cash/gift card that is distributed and filed with the corresponding log. 9. Coordinator (person who requests the TA/PO) will keep a spreadsheet of all gift cards/currency denomination amounts and the name of the person that is handing out the gift card/cash to the participant. (see example spreadsheet) 10. All gift cards/cash will be stored in a locked cabinet or drawer at all times. 11. Random spot audits will be performed periodically to verify that: O O O - All information is being obtained by the participant - The coordinator is logging all information accurately and sending the information to the tax department - To ensure that all gift cards/cash are accounted for and a receipt is provided for all gift cards/cash that is distributed.

Log that will be sent to the Tax Dept.

Example

Log of Gift Cards On Hand

Example