I have a Grant, Now What??! John Hulvey Sponsored Programs Accounting I have a Grant, Now What??! John Hulvey

What we will Cover Today: Terminology Common Misconceptions What happens when an award is issued Managing the Award What information is available to help Questions

Terminology “Department ID” = “Org. Code” = “Grant number”. Account # = Expenditure Code PI = Principal Investigator Facilities and Administration (F&A) = “Overhead” or Indirect Costs (IDC) “Match” = “Cost Share” Match can be “Cash” or “In-kind”. “In-kind normally provided by outside party.

Common Misconceptions All sponsored program awards are “Grants” Also Cooperative Agreements and Contracts This is important because different rules apply PI has full control over funds JMU Policy 2201 states “All funds received for sponsored programs are under the fiscal control of the assistant VP for Finance” Some awards provide flexibility on how funds are used, but most do not.

More Common Misconceptions Because I have outlined expenditures in the grant, I can short-cut University purchasing requirements WRONG. JMU receives ‘cash’ in advance Most awards are issued on a ‘reimbursement basis’ Sponsor can refuse to reimburse unallowable expenses.

What Rules Apply? 1) Award document 2) University policies May include references to specific State or Federal regulations 2) University policies 3) State regulations 4) Federal regulations Nothing can contradict Federal Law. Always follow JMU procedures Almost all questions about sponsored program management can be answered “it depends”.

I have the grant, now what’s going to happen!?

What’s the Principal Investigator’s (PI’s) Role? Researcher, Manager, Accountant. Has DIRECT responsibility for Grant Must complete responsibilities of grant Must comply with all regulatory requirements Must work within approved budget and timeline May delegate workload Does not have Ultimate authority

What happens when Sponsored Programs Accounting receives an award? Note regulatory requirements Review Invoicing requirements Record Close-out date Establish Financial Framework 5xxxxx Dept ID(s); Load the budget based on the budget approved in the award; Mail “Award Binder”

What is in the Award Binder? Provides Grant # (or Dept ID or Org #) Contents Signature authorization instructions PS & eVA Access information Small Purchase Charge Card information Internal budget form Dividers Includes your proposal & award documents Insert your financial printouts & expenditure reconciliations Quick find directories The binder is a ‘tool’; there is no requirement to use it and no one will come to ‘audit’ it. It can help keep award documents together.

What Should I Know to Manage an Award? What is in the approved budget? Budget Justification is also handy 2) What is the project period? Project must be DONE by that date 3) Understand that the sponsor has expectations for how the funds are used. - The budget is the financial representation of the project; not spending the money according to this ‘plan’ may be an indication the project changed. - Most sponsors allow 90-days to ‘close out’ an award; “work” should NOT occur on the “project” during this time. (posting SPCC expenses; writing technical reports; filing financial reports)

Managing the Budget Follow the approved budget and budget justification. NOTE: Some sponsors are not as strict as others in terms of ‘following the budget’. You may contact Sponsored Programs Accounting to determine how much flexibility you have. If you cannot tie an expenditure request to a budget line item, don’t process the request. Sponsors expect changes in the budget. Very hard to predict exactly how a project will go 12 months before it starts.

Procurement and Purchasing What’s the difference between a Contractor and a Sub-recipient? Contractor: Must follow University expenditure processing. Items costing $5000 or more require assistance from Procurement. Inform Procurement about the award budget. eVA is a Requirement Conflict of Interest regulations - Sub-recipient can be views as someone performing a sub-set of the project. (“above the neck” involvement in the project). - In most cases, if a purchasing procedure is required to spend ‘departmental’ funds, they should be completed for sponsored program dollars also.

Managing the Time Work within the approved Project Period Most sponsors tract the project period This date restriction applies to expenses BEFORE the award as well as after. Most sponsors will allow “no-cost extensions”, but often require the request 30-days prior to the ending date. Close-out periods do NOT allow project work to continue. Time is for reporting and final processing. No-cost extensions should not be a last second decision. PI should have a timeline to complete the project by the close-out date

Cost Transfers Defined as ‘moving an expense from one Department ID to another’. Must move expenses, can’t move ‘cash’ Use an Agency Transaction Voucher ATV Transfer expenses INTO the grant. Should only be used in limited situations

Cost Transfers – Continued Cost Transfers should only be used for Personnel expenses or to correct errors Sufficient documentation to track the expense detail will be required Cost Transfers should be processed within 45 days from the time of the original expense posting.

Can I modify my award? Some (most?) projects require some adjustment in the budget or timeline. Work with the Office of Sponsored Programs to modify the budget or extend the project Must receive sponsor’s permission in advance of implementing any change

How do I Manage the Sub-recipients? VERY CLOSELY! New federal regulations (2 CFR 200.330 – 332) require sub-recipient monitoring. Must ensure they are following their approved budget and timeline Must ensure they are completing their assigned work. Their invoices should not be paid without adequate monitoring documented. Invoices from a sub-recipient should only be paid if the PI can confirm the sub-recipient is performing as specified. PI should take any necessary steps to verify this: site visits; technical reports; expenditure reports; etc.)

Close-out Can be considered the “fiscal year end” for the award Generally a cause for rush and panic, and it should not be. Make sure requests to “spend out” the budget are justified to the award and calculated correctly Calculate remaining balance on PARs Remember that FICA tax is added to PAR for salary amounts.

Record Retention Financial records from the beginning of the award need to be maintained up to five (5) years FROM THE CLOSEOUT OF THE AWARD. (Binder might help with this). For multi-year awards, this could mean that financial records would be 7 to 10 years old. Example: Award ends 6/30/2015; final reports submitted 9/15/2015; record retention period ends 9/15/2020. If award began 7/1/2013, those transactions happened over 7 years earlier. Some awards allow a 3-year period; if in doubt, use 5 years. - If a project does not have an ending date, normal University record retention periods apply. Check with Sponsored Programs Accounting if you are unsure of the record retention requirements.

What Records Must be Kept? All expenditure documentation Including monthly reconciliation to 5xxxxx DeptID Personnel and Non-Personnel expenses must be tracked. Collect “matching” data (cost share) Document time employees worked on the project. (Effort Reporting) Document technical work from the project. Maintain all reports submitted to the sponsor.

Review: How do I Avoid Problems Administering an Award? FOLLOW THE AWARD BUDGET! Follow JMU Fin Policies and Procedures Reconcile the DeptID Monthly Limit Cost Transfers (ATV’s) If required, process promptly Complete work within the Project Period (may cross fiscal years) Request budget revisions or no-cost extensions early, as necessary 90-day ‘close out period’ for paperwork only

What Resources Exist to Assist in Sponsored Project Administration? Financial Reports: nVision “C” Report – “Life to Date” Totals with Current Month Details nVision “D” Report – Life to Date totals with Details by Individual line item (by month). Monthly Detail Report nVision Query (by fiscal year) Monthly reconciliation is a requirement

Sample “C” Report

Sample “D” Report - Monthly columns with activity by fiscal year: “2015-4” = October 2014; “2015-11” = May 2015

Where to Get More Information? (cont’d) Contact Sponsored Programs Accounting John Hulvey 83725 hulveyjd@jmu.edu Brenda Wilburn 82314 wilburbc@jmu.edu Donna Crumpton 88099 crumptdl@jmu.edu Kyra Shiflet 87108 shiflekl@jmu.edu

Questions?