Assistant Director – Sponsored Research Administration Contracts & Grants Process at a Research University FSU Alumni Center MAY 5, 2016 Post Award Processes & Effort Reporting Cathi Bass Assistant Director – Sponsored Research Administration

Agenda Post Award Activities Principal Investigator's (PI) Responsibilities Compliance Regulations Budget & Expenditure Monitoring Cost Sharing Award Closeout Effort/FACET

Post Award Activities Award documents have been executed Signed by appropriate institution official Budget number assigned Department/fund/project number Cost sharing expenditure accounting Research can begin Adhere to scope of work Collaboration/subcontracting to other individuals/institutions Status reports Technical reports Payments will be held if not submitted timely

Post Award Activities Spending occurs Personnel – Human Resources policies and procedures Non Personnel – Purchasing/Travel/Subcontract/Non PO policies and procedures Central Offices have role in reviewing allowability of expenditures 90 days prior to award end New funding increment? Request extension if needed/allowed Notify university grants officer in accordance with timelines established Billing/Collecting from agencies (central office responsibility) Financial reporting to agencies (central office responsibility) Amendments (SOW & Budgetary) Contracting Officer for grantor and grantee

Principal Investigator Responsibilities Award is to the Institution, not the PI 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 Ensure commitments are met including cost share requirements Obligations in proposals 2 months of PI’s effort/15% of PI time Must be met whether paid from award or not

Compliance Requirements Federal Uniform Guidance (2 CFR 200) effective December 26, 2014 Effective for new awards/increments (some exceptions) OMB Circulars applicable to University A-21 A-110 A-133 Compliance Criteria “Cost Principles” Direct Costs (personnel, lab supplies, travel) Reasonable Allocable Consistent treatment of costs Conform to limitations or exclusions Facilities & Administrative (F&A) Costs – aka indirect/overhead Negotiated rate with Feds applied to direct costs Agency specific requirements Terms and Conditions in award

Compliance Requirements Non Federal Terms and Conditions rule!! University policies and procedures Topics frequently cited in audits Cost transfers onto or between projects – do it right the first time! Expenditures late in the project – using up available balance Cost share accounting/reporting Effort reporting processes Charging costs normally considered F&A directly to projects Allocation of costs, especially computers and equipment Burn rate – rate of spending on the project in relation to the time period of the award Foreign travel

Budget & Expenditure Monitoring PI responsible for ensuring expenditures benefit the project Timing of when personnel need to be appointed Timing of when supplies will be used Collaboration with subcontractor in accordance with SOW Periodic budget vs. actuals reports Ensure anticipated expenditures are charged to project Review for accuracy of expenditures that post to project Rate of expenditures reasonable for pace of research progress

Cost Sharing Costs not borne by the sponsor Costs must meet “cost principles” Directly benefit the project Types allowed: Personnel Non Personnel Unrecovered Overhead (with agency approval) Tuition Included in proposal must account for cost share expenditures Reporting may be required Cost share amount NOT met may reduce award amount proportionately

Award Closeout SOW complete and final reports submitted Expenditures are complete: All charges incurred during project period are posted Avoid late cost transfers Charges posted allowable Subcontractor SOW complete Final invoice processed timely Effort reported for amount of time expended on project Commitments met Funded or not funded by award

Effort Reporting What is effort? – Amount of time spent on a particular activity, whether directly charged to a project or cost-shared. Expressed as a percentage of the total amount (100%) of time spent on compensated work-related activities Instruction Research/Creative Activity Service/Administration Sabbatical/Leave

Who is required to certify their effort Any Instructor of Record on a course Any employee paid on a sponsored project Any employee working on a sponsored project Any employee with a commitment on a sponsored project

Why Effort Reporting Matters Satisfy Federal requirements – (prior OMB Circular A-21, J.10) – Uniform Guidance 2CRF 200.430 Support Salaries charged (direct & cost-shared) and effort expended on sponsored projects Demonstrate compliance with effort commitments made to agencies Demonstrate compliance with Florida’s 12-hour law through reporting to Board of Governors Florida Statutes, s. 1012.945 Required number of classroom teaching hours for university faculty members

Why Effort Reporting Matters Consequences Institutional Sanctions: fines and penalties; debarment from participating in federally-funded research Individual Sanctions: civil and/or criminal sanctions (fines and imprisonment); debarment from participating in federally-funded research

How is effort tracked? A ssignments C ommitments and F aculty A ssignments C ommitments and E ffort Certification T racking FACET is Florida State University’s official effort reporting system.

FACET Support Contacts Sponsored Research Admin Phone Email Kaytee Fletcher 645-1947 kfletcher@fsu.edu Institutional Research IR-FACET Contact n/a facet@fsu.edu Matthew Earhart 644-4203 mearhart@admin.fsu.edu Mev Verzaal 645-0285 mverzaal@fsu.edu

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