Post Award MUHAS, Dartmouth, UCSF Financial Reporting & Closeouts Tuesday October 21, 2014

Agenda O Foundations of good financial reporting O Types of financial reports O Financial reporting requirements for selected sponsors

ApplicationNotice of AwardAccount Setup Project Implementation Reporting and Publication Closeout Lifecycle of an Award Internal Controls Regulation Contractual Obligations Reporting and Documentation

Foundations of Good Financial Reporting O Starts with account set up which facilitates financial reporting by: O Segregating expenses into separate accounts O Mirror reporting cycle in terms duration of award period and timing of reports O Mirrors the level of detail of reports by either expense type or program activity O Accurate, timely, relevant, useful

Elements of a Good Financial System Expense classifications Provides a clear set of expense types that provide meaningful information and identification of allowable and unallowable costs Transaction level detail Able to record and produce reports with sufficient transaction detail (date paid, vendor, employee, amount, reference number, etc) Direct versus Indirect costs Able clearly distinguish direct costs versus application of a rate for indirect costs Records fiscal year Able to “close” transaction data on both a monthly and fiscal year basis Discussion: What are other “essential” elements? What are “nice to haves?”

More Considerations for a Financial Reporting System O Official records (not a shadow system) that is incorporated into the institution’s financial statements O Users should have clarity on who enters data into the system and when (who to call if something doesn’t look correct) O Tools should be easy to use, on-line O Standard reports should be made available to facilitate sponsor reporting O Allow downloads of data to facilitate reconciliation and projections.

Financial Reporting: Roles and Responsibilities O Who is responsible for preparing and submitting financial reports? O Centralized? Decentralized? O What are the checks and balances to assure that reported amounts tie to your “system of record”? O Is there need/value in having separation of duties between the administrator that initiates transactions and the person submitting the report?

Types of Financial Reports Sponsor reporting Most sponsors require (even gifts sometimes) Award requirement Assures stewardship and accountability to tax payers and donors Usually ties to cash Identifies amounts to carryover Principal Investigator reporting Management tool Compliance tool for allocability and relation to objectives Division reporting Plan resources Strategic planning Productivity Institutional reporting Financial statements Audits Strategic planning

Discussion: Do you have any awards with cost sharing or matching requirements? O How do you track the cost sharing? O How do you demonstrate that you have met your obligation to an auditor?

NIH Financial Reports Federal Financial Report (FFR)(SF-425) Expenditure Data O Timely - Must adhere to submission deadlines: O Annual – O FFR submitted for each budget period no later than 90 days after the end of the calendar quarter (CQ) in which the budget period ended.  Budget period ends 1/31/2011 – FFR due 6/30/11 (90 days after the end of the CQ of 3/31/11) O Final (End of Competitive Segment) – FFR submitted within 90 days following the end of the project period Uniform Guidance makes stricter rules

NIH Reporting Requirements O Progress reports are required at least annually O The Non-Competing Continuation Progress Report (PHS 2590)Non-Competing Continuation Progress Report O Progress reports must be submitted electronically using the Research Performance Progress Report (RPPR)

90 days OSP reminds PI and staff of end date Discuss need for no-cost extension Reminds PI of technical reports 60 days Reviews expenses incurred not paid Reviews appropriate charges that can made to the grant Contacts Subcontractors to remind of final bill due within 45 days of end date 30 days Establish new account number if another year Prepare paperwork to move salary to new accounts Notify PI and staff of new account Grant Close Financial Report Preparation Prepare final reconciliation Identify pending expenses Collect final subcontractor invoices Prepare report for submission within 90 days Sample Report Timeline Before End Date of GrantAfter End date

Terminology O Closeout: process by which all applicable administrative actions and all required work of the award have been completed O Total expenses = Cash received O Reports filed, usually include: O Final Financial Report O Final Progress Report O Final Invention Statement

Unobligated Balances and Carryover O Disposition of unobligated balances is determined by the award notice and sponsor terms O If the award is unclear, ask for clarification O Some sponsors will allow a request to carryover unspent funds to be used in the next year; some will not O Always put requests in writing and submit to the appropriate sponsor official (for NIH, it’s the grants specialist, not the Program Officer)

Uniform Guidance and Financial Reporting O The non-Federal entity must submit, no later than 90 calendar days after the end date of the period of performance, all financial, performance, and other reports as required by or the terms and conditions of the Federal award. The Federal awarding agency or pass- through entity may approve extensions when requested by the non- Federal entity. O Unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all obligations incurred under the Federal award not later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. O The Federal awarding agency or pass-through entity should complete all closeout actions for Federal awards no later than one year after receipt and acceptance of all required final reports. O Expect that US federal sponsors will act more quickly in closing grants and may do so unilateraly O As a subrecipient, expect shorter time frames for reporting and invoicing

References

NIH Financial Reports O NIH Updating Grant Closeout Policies and Procedures to Align with New HHS Requirements Notice Number: NOT-OD O Anticipated changes will focus on condensing the timeframe for reconciling discrepancies between financial expenditures and cash transactions reports and for resolving other post-submission issues affecting acceptance of the final Federal Financial Report (FFR) – O NIH Grant Closeout Forms: O Frequently Asked Questions Grants Closeout