Overview Post-award Issues for the Pre-award and Departmental Administrators What does this mean for you, for your institution?

Overview Fine line between pre and post award Handled within one office or two Thorough knowledge is needed from proposal preparation to closeout

Overview To more effectively and efficiently manage research Discussion on a proactive approach to working together

Outcomes Impact that pre and post award has on the other Impact of the proposal and negotiation process on the PI Departmental administrators will understand the needs of pre award administrator (and visa versa)

The Research Cycle Proposal Award Performance Closeout Audit

Award Instruments Grant Contract Cooperative Agreement

Definition: Grant Purpose is to transfer money, property, services or anything of value to recipient in order to accomplish a public purpose No substantial involvement anticipated between government and recipient

Definition: Contract Purpose is to acquire property or services for direct benefit or use of the federal government Very restrictive. No expectation of cost sharing

Definition: Cooperative Agreement Purpose is to transfer money, property, services or anything of value to recipient in order to accomplish a public purpose Substantial involvement anticipated between government and recipient

Principal Investigator Prep of programmatic proposal Development of project budget Monitor programmatic and financial performance Adhere to terms and conditions of award

Principal Investigator Closeout: Final progress report, invention statement. Financial responsibility and audit

Departmental Administrator Assists and advises the PI in preparation of proposal, in accordance with sponsor terms and conditions, applicable regulations, institutional policies

Departmental Administrator Assists PI in compliance with award terms and conditions, regulations, institutional policies

Departmental Administrator Monitors expenditures of award funds, obtains necessary authorized signatures

Departmental Administrator Coordinates with central offices on reporting

Departmental Administrator Assists central administration with closeout and audit activities

Sponsored Programs Office Review of Proposals for Regulatory and Policy Issues Ensure Proper Sign-offs Negotiate Agreements Approve Certain Transactions

Review of Proposals Review of RFP, BAA, Program Announcement for terms that may be problematic What is PI promising that department and post-award staff have to comply with?

Ensure Proper Sign-offs Who is Authorized to Approve Proposals/Commit resources? Who Can be PI? Acceptance of Risk (Overruns, Cost Sharing, Under-recovery of F&A)

Negotiate Agreements Does contract have requirements that are “non-standard” Who will non-standard terms impact? Will they accept the terms?

Negotiate Agreements Examples of non-standard requirements: Monthly progress reports Quarterly invoices Sponsor retains title to equipment after period of performance

Approve Transactions OSP should notify post-award administrators of award terms in advance of spending. For example, equipment purchases, travel approval, other “special” requirements of sponsor.

Grant/Contract Acctg Review accounting transactions based on allowability criteria, terms and conditions, and agency guidelines. Review such transactions for compliance with University guidelines.

Grant/Contract Acctg Review for proper signatures Review for fund availability Prepare billings and financial reports Collect cash

Grant/Contract Acctg Maintain effort reporting system Advise PI and departmental administrators on financial matters Coordinate A-133 and other audits

Shared Responsibilities Stewardship and accountability Effective management of public funds

Communication Challenges Sponsor/Institutional Policies Face-to-Face Meetings Websites with up to date information Electronic tools

Getting Stakeholders on the Same Page Transmit a copy of award document Inform key staff of award terms and conditions Ensure key staff know and understand responsibilities Dialogue during performance period

Time is of the Essence Identify problems early and resolve problems as soon as possible and with as few parties involved as necessary to reach a solution. Attempt to resolve problems promptly Make sure all involved parties understand the issue Know when to involve the sponsors

Pre-Award/Post-Award Offices: A Team Effort Understanding each other’s roles & responsibilities Conduct joint staff meetings Conduct joint discussions with departmental staff Project a team approach to resolve issues

Improving Communication Early review of program announcements, solicitations, RFP, etc

Improving Communication Identification of unusual sponsor requirements, e.g. reporting

Improving Communication Discussion of problematic terms prior to proposal submission

Improving Communication Communications with sponsor, avoiding “informal” agreements

Issues in Proposals Office Supplies Computers Cost Accounting Standards Office Supplies Computers General Purpose Equipment Local Telephone

Issues in Proposals 5. Dues and Subscriptions 6. Unallowable Cost 7. Know your institution’s policies

Direct Charging of Administrative Costs OMB Guidance on A-21 Revision to section F. 6. (b) (July 1993) “In developing the departmental administration cost pool, special care should be exercised to ensure that costs incurred for the same purpose in like circumstances are treated consistently as either direct or F&A costs ...”

Direct Charging of Administrative Costs OMB: “Direct charging ... may be appropriate where a major project or activity explicitly budgets for administrative or clerical services”

Direct Charging of Administrative Costs Do we explicitly budget for these costs in the research proposal? Does the proposal include a written justification (why costs are necessary for project performance) Is this a “major project” as defined in A-21 and Exhibit C?

Direct Charging of Administrative Costs Are administrative and clerical costs approved by the Sponsor? Is there a record of this for audit? Effort report must reflect actual time spent –consistent with approved proposal budget

Proposal Budgets Required by Sponsor or volunteered by investigator Cost Sharing Required by Sponsor or volunteered by investigator University commitment Impact of F&A rate

Effort Reporting Definition: A method of certifying time spent on a research grant, and justifying salary expense charged to sponsor

Effort Reporting Regulation OMB Circular A-21, Section J.10 “Compensation for personal services” J.10.b. Payroll Distribution requirements

Effort Reporting Direct charged? Cost Shared? What effort is committed in the proposal? Direct charged? Cost Shared? Commitments must be tracked

Effort Reporting Issues Multiple sources of pay (e.g., faculty practice plan) NIH salary cap Summer salaries Cost transfers not incorporated into certification

Effort Reporting For personnel whose salaries are charged (or cost-shared) to research grants and contracts Effort should be certified by “responsible persons with suitable means of verification that the work was performed”

Effort Reporting Per A-21: System will provide for independent internal evaluations to ensure compliance How does this happen at your institution?

Issues in Proposals Proposing the correct rate Facilities and Administrative Rate Proposing the correct rate Research, instruction, other sponsored activity

Issues in Proposals 3. Regular rate or special location rate 4. On Campus or Off Campus Rate

Program Income Definition (A-110) Gross income earned by the recipient that is directly generated by a supported activity or earned as a result of the award

Program Income 1) Add to Award 2) Use to Fund non-Federal Share Will Award Generate Program Income? What Do We Do With Income? 1) Add to Award 2) Use to Fund non-Federal Share 3) Deduct from Total Project

Subcontractors Scope of work Budget Institutional commitment (OSP) Proposals including subcontracts should include: Scope of work Budget Institutional commitment (OSP)

Subcontractors Is this a Subcontract or Consultant relationship? Independent line of inquiry or providing service or expertise? Difference in F&A treatment Difference in ownership of IP

Subcontractors Approval of Subcontract Invoices PI should judge whether progress is satisfactory Dept Administrator should determine whether subs costs are appropriate, within the period of performance

Who can perform the audit Audit timetable Record retention Issues in Proposals Audit Requirements Who can perform the audit Audit timetable Record retention Notification requirement

Acceptance and Assignment of Financial Risk Institutions authorized recipients Document and report project costs Institutional policies for cost overruns on project

Payment Terms Advance Payments Cost Reimbursement Payments Progress Payments based on milestone deliverables

Payment Terms Frequency Invoices and backup documentation

Payment Methods Letter of Credit Draws Electronic Fund Transfer Checks

Reporting Requirements Contracts with unusual Reporting Requirements may be a problem Reporting of labor hours worked Detailed expenditure reporting Monthly Progress Report

Reporting Requirements Pre-Award Must Communicate the Types of Reports, Frequency of Reporting, Due Dates Contract reporting requirements more onerous than grants May be penalties for late reports

Reporting Requirements Types of Reports Technical/Progress (PI) Patent/Invention (PI) Fiscal (Sponsored Accounting) Property (Asset Accounting)

Reporting Requirements Pre-award office may be tasked with pursuing late reports Correct report distribution info can minimize late reports Timely reporting requires coordination

Performance Issues Approval of project expenditures Documentation of project expenditures

Closeout Responsibilities Reaching the termination date of a project does not signal the end of our responsibilities Institutions have sponsor requirements to fulfill before we can closeout the award

Closeout Responsibilities Financial Accounting Costs must be allowable, allocable, reasonable and consistent with the terms of the agreement Good project management over the life of the award will help to eliminate any problems after the award has ended

Closeout Responsibilities Financial Accounting Pre-Award must communicate the with the Dept/PI Is this a Fixed Price agreement or Cost Reimbursement What is the process for an extension? Prior approval needed? Carry-forward of funds allowed?

Closeout Responsibilities Financial Accounting Departmental Administrator and PI must ensure that all costs are necessary for the performance of the project, incurred within the period of performance and charged to the project within the specified period (e.g. within 90 days of termination).

Closeout Responsibilities Reporting Financial Reports: Have all project expenditures been posted? Technical Reports (PI): Submitted timely (or at all)? Appropriate and complete information (Award #, PI name, title, etc.)? Proper report distribution?

Closeout Responsibilities Reporting Invention Reports: Have reports been filed, using appropriate forms (see Campbell Plastics) Property Reports: Who owns equipment, what is disposition, when was equipment purchased?

Audit Responsibilities Anticipate the project will be audited Audits often take place after the project is completed and several years after the expenditures were incurred

Audit Responsibilities OMB A-110 “The Federal awarding agency…or any of their duly authorized representatives, have the right of timely and unrestricted access to any books, documents, papers, or other records of recipients that are pertinent to the awards.”

Audit Responsibilities OMB A-110 “This right also includes timely and reasonable access to a recipient's personnel for the purpose of interview and discussion related to such documents.”

Audit Responsibilities If records are requested and interviews are conducted for an audit which takes place several years after expenditures were incurred, will we be prepared to justify and support that the expenses are direct project costs?

Audit Responsibilities Documentation is the key to being prepared for an audit Are project effort reports signed? Is cost sharing documented? Procurement expenditures properly documented?

Audit Responsibilities Record Retention Financial records, supporting documents, statistical records, and all other records pertinent to an award shall be retained for a period of three years from the date of submission of the final expenditure report (A-110)

Audit Responsibilities Question: When is the best time to prepare for an audit? Answer: Now (and throughout the project)!