Research Administration for Scientists Tim Quigg, Associate Chair and Lecturer Computer Science Department, UNC-Chapel Hill OMB Circular A-110: Administrative Requirements COMP 918: Research Administration for Scientists © Copyright 2012 Timothy L. Quigg All Rights Reserved

Research Administration for Scientists A-110 Administrative Requirements Uniform administrative requirements for grants and agreements (not contracts which are subject to the FAR) with institutions of higher education, hospitals and other non- profit organizations Federal agencies shall not impose additional or inconsistent requirements … unless specifically required by law or executive order.

Research Administration for Scientists A-110 Administrative Requirements  Financial Management Systems  Program Income  Budget and Program Revisions  Expanded Authority  Equipment  Intangible Property (Patents, Copyright and Data)  Procurement Standards  Reports and Records (Performance and Financial)  Termination  Close-Out Procedures  Cost Share  Recharge Centers

Research Administration for Scientists Financial Management Systems  Accurate, current and complete accounting of financial results by project  Comparison of expenditures with budgeted amounts  Written procedures to determine allocability and allowability of costs (consistent with A-21)  Effective control over and accounting for funds and other assets (including equipment – asset accounting system)

Research Administration for Scientists Financial Management Systems  Written procedures to minimize the time elapsing between the transfer of funds from the U.S. treasury and payment of project expenses.  I often hear faculty ask, has the check for my grant money arrived yet?  It would be nice if the system worked that way, but it doesn’t. So how are funds transferred from the U.S. treasury to the university?

Research Administration for Scientists Two primary methods for transfer:  Weekly (or periodic) electronic “draw down”  estimate of financial requirements for the coming week (period) for all awards from that agency  penalties (paying interest to feds) if excessive  separate process for each agency (NIH, NSF)  Invoice – Reimbursement  incur the expense first and then request “reimbursement”  can be either electronic or paper process  significant delay! Who finances the “float time”?

Research Administration for Scientists Program Income Examples:  Fees for services  Rental of property acquired under award  Sale of items fabricated under award

Research Administration for Scientists Program Income  Added to project and used to further project objectives  Used to finance the non-federal share of project (must be approved at proposal time)  Deducted from federal funds IMPORTANT: If you anticipate having program income, disclose it at proposal time to obtain required prior approvals!

Research Administration for Scientists Budget and Program Revisions Prior approval from awarding agencies is normally required for:  Change in the scope or objectives of project  Change in key personnel (specified in proposal and award)  Absence for more than 3 months or a 25% reduction in effort by the PI  Need for additional federal funding  Transfer of funds between direct and indirect costs and from training allowances to any other category  Sub awards unless included in application and approved in award

Research Administration for Scientists Expanded Authority Agencies may allow recipients to develop their own systems (IPAS) for approving certain actions:  Incur pre-award costs 90 days prior to award  Expenses must be consistent with budget  All pre-award costs are at recipient’s risk  Can go more than 90 days with agency approval  Initiate a one-time no-cost extension of the project period for up to one year  10 days prior to expiration date  Provide reasons (fund balance is not a reason)!  Carry forward balances to subsequent funding periods

Research Administration for Scientists Equipment  Title vests with recipient (usually)  When project ends, residual equipment must be used for: 1. Other projects funded by same agency 2. Other federally funded projects  Must have adequate property management system

Research Administration for Scientists Intangible Property: Patents

Research Administration for Scientists “March-in” Rights!

Research Administration for Scientists Intangible Property: Copyright

Research Administration for Scientists Intangible Property: Data

Research Administration for Scientists Procurement Standards

Research Administration for Scientists Program Performance (Progress) Reports: PI Responsibility

Research Administration for Scientists Financial Reports: Institutional Responsibility

Research Administration for Scientists Termination

Research Administration for Scientists Closeout Procedures

Research Administration for Scientists Cost Share

Research Administration for Scientists Cost Share

Research Administration for Scientists Cost Share

Research Administration for Scientists Cost Share

Research Administration for Scientists Types of Cost Share

Research Administration for Scientists

Timing of Cost Share

Research Administration for Scientists Examples of Cost Share

Research Administration for Scientists Sources of Cost Share

Research Administration for Scientists Unallowable Cost Share

Research Administration for Scientists Repercussions of Unmet Cost Share

Research Administration for Scientists Recharge Centers

Research Administration for Scientists Examples of Recharge Centers

Research Administration for Scientists  Service Center/Service Facility:  $50,000 - $1,000,000/year  Usually not university-wide in scope  Special Service Facilities (SSF):  A-21 Section J.44 – “institutional services involving the use of highly complex or specialized facilities such as electronic computers, wind tunnels, and reactors …”  University-wide in scope  > $1,000,000/year  Recharge Center:  < $50,000/year Alternate Names

Research Administration for Scientists  The charge for each service must include allowable direct costs; and when appropriate, the allocable share of facilities and administrative costs.  Recharge Centers may be (and often are) subsidized using non-federal funds.  Users should be directly billed for each service based on a schedule of rates that does not discriminate between federally and non-federally supported activity.  However, it is permissible to charge external users a higher rate! Characteristics

Research Administration for Scientists  Goal is to operate on a break basis – Rates should not recover more than the total cost of the center over a long-term period. A period is normally defined as one year.  If a substantial balance exists in the recharge center account at the end of the period, it is assumed the rates were too high. They must be lowered for the next period.  Likewise, if there is a negative balance in the recharge center account at the end of the period, it is assumed the rates were too low. They must either be raised for the next period or the center must be subsidized with non-federal funds. Characteristics

Research Administration for Scientists Certain costs such as depreciation on capitalized equipment should be included in either the university’s F&A cost proposal or in the fees of a Recharge Center. If the cost for the same piece of equipment is included in both the F&A rate proposal and a Recharge Center fees, there is the potential the federal government could be double charged for the same cost. This is not allowed! Relationship BTW F&A and Recharge Center Operation/Costs

Research Administration for Scientists Depreciation prorates a portion of the acquisition cost of “capitalized” equipment to each accounting period during which the equipment is in use. The Recharge Center must pay for the equipment in the year of acquisition, but may only include in its rates the IRS allowable depreciation amount each year (straight-line depreciation method)  Automobiles – 4 years  Computers – 6 years  All other equipment – 10 years Equipment Capitalization

Research Administration for Scientists  May include commercial entities as well as students, faculty, or staff acting in a personal capacity (versus in their student or employee role within the University).  Inappropriate outside use of recharge facilities could jeopardize the university’s tax-exempt status. We aren’t running a business!  Umstead Act – North Carolina specific – prevents universities from competing with private business! Issues with External Customers: