GRANTS: CRADLE TO GRAVE ALUMNI CENTER BALLROOM MAY 6, 2014 Post Award Processes & Effort Reporting Roberta McManus Associate Director – Sponsored Research Administration

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 2

Post Award Activities Award documents have been executed Award documents have been executed  Signed by appropriate institution authority Award is to FSU, not the PI Proposal and Award number Project number assigned – budget activated!  Cost sharing accounting Research can begin  Adhere to scope of work  Collaboration/subcontracting to other individuals/institutions Monitoring of activities - documentation Monitoring of activities - documentation  Status reports  Technical reports Payments will be held if not submitted timely Payments will be held if not submitted timely Hold up future awards!! Hold up future awards!! 3

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 4

Post Award Activities 90 days prior to award end  New funding increment?  Request extension if needed/allowed  Notify university grants officer in accordance with timelines established 5

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  Obligations in proposal and/or award documents 2 months of PI’s effort for academic term 15% of PI’s time for fall semester  Must be met whether paid from award or not Monitor subcontractor performance 6

Award Closeout SOW complete and final reports submitted Expenditures are complete:  All charges incurred during project period are posted Avoid late cost transfers Avoid late cost transfers  Charges posted allowable Necessary and benefit the award Necessary and benefit the award Subcontractor  SOW complete  Final invoice processed timely Effort reported for amount of time expended on project Commitments met Funded or not funded by award Funded or not funded by award 7

Compliance Requirements Federal  New Federal guidance issued December 2013  Effective for awards/increments issues on/after December 26, 2014  OMB Circulars applicable to University A-21 (more on this later!) A-110 A-133 Available on SR website at:  Agency specific requirements  Terms and Conditions of award Non Federal  Terms and Conditions rule!! FSU SR Related Policies and Procedures  8

OMB Circular A-21 SRS/SRAS use this resource daily Allowable means:  Reasonable (prudent person)  Allocable (relative benefits)  Treatment is consistent (direct vs. indirect)  Conforms to limitations or exclusions (e.g. salary caps) Direct costs  “identified specifically with a particular sponsored project” Facilities & Administrative (F&A) costs  “incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular sponsored projects” 9

OMB Circular A-21 Cost Accounting Standards (CAS) Selected Cost Items (Section J)  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 10

SR Financial Policies/Procedures Advances Advances Cost Accounting Standards (CAS) Cost Accounting Standards (CAS) Cost Sharing Cost Sharing Cost Transfers Cost Transfers Effort Effort Commitments Fixed Price Residual Funds Indirect Cost Recovery Participant Support Costs Program Income Subrecipient Monitoring Unallowable Costs 11

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) 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 Transfers will not be approved 12

Cost Transfer Policy Ensure that funds are properly managed Indicators of inadequate fiscal monitoring  Frequent cost transfers  Late cost transfers  Inadequately documented or justified cost transfers Examples of improper/unallowable cost transfers  Utilizing unexpended funds  Moving overrun on one project to another project  Moving unallowable costs on one project to another project  Circumventing award restrictions  Reimbursing a temporary “loan” of funds from another project 13

Cost Transfer Policy Proper cost transfers  The transfer represents an adjustment for an erroneous charge  Split purchase Timeliness  Essential to evidence sound fiscal management  Monthly reconciliations!!!!! Policy  Payroll/Non Payroll Within 90 days of end of the month in which error occurred OR Within 90 days of end of the month in which error occurred OR Within 30 days of the project expiration date Within 30 days of the project expiration date Must complete Cost Transfer Justification Form SRA Cost Transfer Committee  Assistant Director –SRA Accounting Chairs 14

Cost Accounting Standards (CAS) FSU is required to disclose “costing practices” in a formalized document (Disclosure Statement-2) Describes how FSU treats  Direct  F&A costs Facilities Administration 15

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 16

CAS Exception Process Must be documented for all federally-funded awards Pertains to direct charge costs that are normally treated as indirect costs  Personnel  Non-personnel Inclusion in the budget in the award document does not automatically grant the exception Form at Justify exceptional circumstance Submit to Sponsored Research Administration 17

Cost Sharing Policy at haring.html haring.html Procedures at ments/csprocedures.pdf ments/csprocedures.pdf Definition = Costs not borne by FSU Criteria for tracking/reporting  Committed – Mandatory vs. Voluntary Committed  Must account for and report  “Project Enhancement”  Do not have to account for and report 18

Cost Sharing Include in the proposal budget  Cost Share Commitment Form  Signed by Chair/Dean/Director Cost Share budgets are set up in OMNI  Sponsored award/cost share budget set up same time  Important to get cost share info to SRA or will hold up being able to spend Does not include 3rd party Transfer cash when using these funding sources:  PI Support projects  SRAD projects  FSU Foundation  FSU Research Foundation 19

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.) 20

Budget & Expenditure Monitoring Award is to the University…however 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 (OMNI)  Ensure anticipated expenditures charged  Review for expenditures that do not belong on project  Rate of expenditures reasonable for pace of research progress  Expect/Request expenditure reports  Personnel – staff charged/encumbered  Non-personnel 21

SRA Review of Expenditures Requisitions > $1,000 Travel and Expense reports > $1,000 Unencumbered expenses (pay requests/participant requests) >$1,000 All personnel appointments  Payroll cost transfers (Retroactive Distribution of Funding – RDF)  Cost Transfer Justification Form All journal entries  Cost Transfer Justification Form All interdepartmental requisitions  Sales between departments (stockrooms, machine time, etc.) 22

SRA Review of Expenditures Compliance Evaluation Criteria  Authorized Signature Sponsored Project Manager or PI Sponsored Project Manager or PI  Chartfield Information DeptID, Fund Code, Project Combination DeptID, Fund Code, Project Combination  Performance Period Goods or Services received and consumed within begin/end dates of award Goods or Services received and consumed within begin/end dates of award Available Balance  Direct cost budget check Budget category line item Budget category line item FDP/RTC FDP/RTC 23

SRA Review of Expenditures Account or Job Code  Appropriate for nature of expense Allowable  Remember OMB Circular A-21!  Terms and Conditions support expense 24

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

OMNI Overview Financial/Human Resource Systems Project financial information  Job Aids on Division of Sponsored Research at Available project balance inquiry Generating project financial report Running query of project expenditure detail Generating HR report of payroll detail  Budget check against direct cost budget  Expenditures (costs incurred)  Encumbrances (POs, T-Auths, personnel appointments)  Not encumbered (future personnel appointments, tuition, rent, F&A) 26

PI Resources 27

Training Opportunities CReATE – Compliance and Research Administration Training and Education  Next session Fall 2014  New Federal guidance SRA Certificate Series  Curriculum geared toward support staff  Hands on tools  Summer schedule in process  Schedule posted at 28

Web Resources Office of Research ( Division of Sponsored Research (  Staff Contact Information (SRAS assignments attached)  Policies and Procedures  Forms  Funding Resources  OMNI Information  Training Information  /Newsletter Services (recommend getting on these list serves) 29

Web Resources Controller’s Office (  General Accounting  Payroll Services  Property Accounting  Accounts Payable  Travel Office of Graduate Studies (  Matriculation Waiver Information Purchasing ( Human Resources ( OMNI Resources ( 30

Contact Information SRA Assignment Sheet ff.pdf ff.pdf 31

QUESTIONS 32