Policy? Guidance? Standard Operating Procedure? Tips on how to achieve compliance with minimum red tape Carolyn Bargoot, Associate Director Post-Award.

Slides:



Advertisements
Similar presentations
MONITORING OF SUBGRANTEES
Advertisements

Massachusetts Department of Elementary & Secondary Education
What You Need to Know To Ensure Compliance October 2014.
Dr. Chellu S. Chetty Associate VP for Research and Sponsored Programs February 23, 2010 Time and Effort Reporting.
A-21 From budgets to post-award…. Agenda What is A-21? – quick overview Budget categories captured by A-21 Proposal budgets and A-21 (overview and tips)
Practitioner psychologist education seminar. Today Welcome Introduction to HPC Workshop 1: Working collaboratively Break Workshop 2: Working with the.
Prepared by the Office of Grants and Contracts1 COST SHARING.
CSBG Policy and Procedures A Multi-Faceted and Useful Tool.
Congratulations on being awarded a grant! NOW WHAT?
OMB Circular A-21 Cost Principles for Educational Institutions.
DIVISION OF RESEARCH Utilization of Minority-Owned and Women- Owned Business Enterprises in New York State Sponsored Projects Fall 2009 Kimberly Klatt.
Project Management: Post Award Policies, Procedures and Guidelines A Tutorial for New Principal Investigators.
Business Procedures Manual MSBO 2014 Mike Radke, Director Field Services – Michigan Department of Education Rebecca Rocho, Asst. Superintendent / Legislation.
UNIFORM GUIDANCE OVERVIEW. OMB Circulars Before and After A-21 Cost principles for Educational Institutions A-21 Cost principles for Educational Institutions.
OMB Uniform Guidance 2014 Implementation at the University of Washington Northwest Chapter of Internal Auditors August 5 th, 2014 Ted Mordhorst Asst. Dir.
Big Lottery Fund Improving your chances of success Sarah Carroll Funding Officer (Local) 16 July 2014.
Financial Policies You Cannot Live Without - Setting Priorities in a new Job at a PUI NCURA FRA 2013 Conference New Orleans, LA.
What You Need to Know To Ensure Compliance January 2015.
Financial Management For Project Administrators. How Feds View Themselves.
Course Textbook Adoption Ordering and Compliance.
Cambridgeshire Pension Fund Administration Report Cory Blose.
Basic Research Administration Principles Presented by Ronald Kiguba Research Coordinator, Makerere Medical School.
1 COST SHARING CReATE ver. 04/13 © 2013 Florida State University. All rights reserved Objective: To understand the requirements related to cost sharing.
Federalwide Assurance Presentation for IRB Members.
Staff Structure Support HCCA Special Interest Group New Regulations: A Strategy for Implementation Sharon Schmid Vice President, Compliance and.
Audit and Fiscal Oversight Responsibilities VAVRINEK, TRINE, DAY & CO., LLP December 15,2010.
Writing job descriptions The Easy Way! 1. Why Job Descriptions? *Helps the HR department to determine the right pay range *Attract the right candidates.
1 INTERNAL CONTROLS Matthew Pakos School Improvement Grant Programs May 23, 2011.
1 Module 4: Post-Award Administration of Sponsored Projects (Part 1) Office of Research and Sponsored Programs The University of Mississippi 100 Barr Hall.
MANAGING SPONSORED PROJECTS FINANCIAL COMPLIANCE May 1, 2008 Office of Grants &Contracts Accounting.
Northamptonshire Pension Fund Administration Report Beth Sargent.
Cost Principles – 2 CFR Part 200 Subpart E U.S. Department of Education.
Conservation Districts Supervisor Accreditation Module 9: Employer/Employee Relations.
Fundamentals of Evaluation for Public Health Programs ROBERT FOLEY, M.ED. NIHB TRIBAL PUBLIC HEALTH SUMMIT MARCH 31,
Bridging the Gap: Research Administration and Proposal Development Brigette Pfister, MHRD, CRA Trisha Southergill, MPA, CRA Jessica Venable, MA.
1 The Auditor’s Perspective Division of Sponsored Research Research Administration Training Series Presented by: Joe Cannella Audit Manager,
Time with Office of Sponsored Programs April 4, 2011 Topic: Cost Share.
Sponsored Programs Services (SPS) PROPOSALS. What is the PI’s role in the proposal?  Contact the central pre-award center,
Stay on Top of Your Perkins Grant: Surviving Monitoring Visits and Audits May 2009 Renee Kuharski, Ph.D. Colorado Mountain College.
STRENGTHENING HISTORICALLY BLACK COLLEGES AND UNIVERSITIES (HBCU) PROGRAM.
Managing Your Grant Award August 23, 2012 Janet Stoeckert Director, Research Administration Sr. Administrator, Basic Sciences Keck School of Medicine 1.
SBIR Budgeting Leanne Robey Chief, Special Reviews Branch, NIH.
Cost Sharing for Sponsored Programs College of Agriculture, Food, and Natural Resources March 19, 2010.
New NSF Awardee Checklist Requirements: WHY? November 19, 2014 joyce y. JOHNSON POST-AWARDS COORDINATOR OFFICE OF SPONSORED PROGRAMS.
Debra Murray, Georgetown University Tolise Miles, Children’s National Medical Center Clairice Lloyd, Georgetown University Medical Center Pre-Award and.
Brette Kaplan, Esq. Erin Auerbach, Esq. Brustein & Manasevit, PLLC Spring Forum 2013
Webinar for FY 2011 i3 Grantees February 9, 2012 Fiscal Oversight of i3 Grants Erin McHughJames Evans, CPA, CGFM, CGMA Office of Innovation and Improvement.
DEVELOPING AND MAINTAINING A TITLE III POLICY AND PROCEDURES MANUAL HBCU TITLE III ASSOCIATION TECHNICAL ASSISTANCE WORKSHOP JUNE 24, 2014 Mrs. Cheryl.
The New OSP Website (& Social Media) Eric Dorman Department Administrator Office for Sponsored Programs March 20, 2015.
NOAA Cooperative Institutes John Cortinas, Ph.D. OAR Cooperative Institute Program, Program Manager NOAA Cooperative Institute Committee, Chairperson.
Daily Management of Awards Jennifer Crockett Jennifer Crockett, Director, Sponsored Projects Finance, Columbia University Tamara Hill Tamara Hill, Manager,
Prepared by the Office of Grants and Contracts1 The Basics of Grants Administration.
Other Strategies for Planning. Outsourcing strategies This strategy includes: Using external individuals or organizations to complete some tasks This.
Post-Award basics MATTHEW MOORE ASSOCIATE DIRECTOR, POST-AWARD OPERATIONS.
1 Research Compliance at HMS: What is it Why it is important Who is involved How it affects you and how you can get help Postdoctoral Fellow Orientation.
Sheraton University Inn December 15, Faculty Member – Principal Investigator (PI) has a research question they want to explore Group of researchers.
ISO DOCUMENT CONTROL. ISO Environmental Management Systems2 Lesson Learning Goals At the end of this lesson you should be able to: 
Preparation Plan. Objectives Describe the role and importance of a preparation plan. Describe the key contents of a preparation plan. Identify and discuss.
WHAT THEY ARE, HOW THEY CHANGE MRAM MARCH 2014 OFFICE OF SPONSORED PROGRAMS GRANTS INFORMATION MEMORANDA.
Cost Sharing on Sponsored Awards Division of Financial Affairs OSP Roundtable October, 2015.
Preparing for External Audit Presented by Sponsored Programs Accounting 2012.
Internal Control Process at Geneseo. Objectives Understand the objectives of effective internal controls Describe Geneseo’s internal control program Accurately.
“The Role of CPSB and CASB in the Transformation and Growth of Counties” By CS Peterson Mwangi.
Grant Management and Compliance
Coffee with Office of Sponsored Programs
Proposal Routing Overview
Federal Grant Programs Conference October 23, 2017
Subrecipient vs. Contractor Determinations
Managing Federal grants
Uniform Guidance Audit: Overview, Timeline and Contacts
Presentation transcript:

Policy? Guidance? Standard Operating Procedure? Tips on how to achieve compliance with minimum red tape Carolyn Bargoot, Associate Director Post-Award Administration Sheila Freedman, Associate Director Audit and Compliance Office for Sponsored Programs, Boston College 1

Agenda – Policy When is developing a policy necessary? How should you go about creating a policy? – Guidance When issuing guidance might be the right path to choose – Standard Operating Procedures (SOP’s) Why develop SOP’s? How can they help you and your institution? 2

Boston College Fun Facts – FY12 – Located in Chestnut Hill, MA – Total Undergraduates 9,100 – Total Graduate Students 4,900 – Total Operating Expenses $795.7 million – Sponsored Awards $51.5 million – Research $31M – OSP Staff = 12 – No A-133 audit findings! 3

Why Develop Policies? – OMB Circulars A-110 requires certain policies A-21 further restricts A-133 tests you on your policies – Funders expect we have certain policies – Ensure compliance 4

You should know You are always bound to your institutional policies University and OSP Policies In most cases it is best NOT to introduce new polices, unless something more is required by Federal or State funding agencies or by law. It is important to remember if your policies are stricter than required you need to make sure that your systems and administrators can meet those stricter requirements. 5

Policy Development – Research What is required for your institution? What type of institution are you? Look at what other similar institutions are doing (websites) Higher Ed is big on sharing -Reach out to other institutions directly – Analysis What would work best for your institution What does your institution need to include in the policy for compliance, regulatory or other purposes? – Consult within your department – Consult with other departments Most policies today affect multiple departments, therefore to be successful you must identify who needs to be part of the process and get their cooperation and buy-in – Consider whether a policy is the right method! 6

Include in your Policy – Clear Purpose – Scope – Assumptions – Requirements – Define Key Terms – Reference federal, state or other pertinent regulations 7

Successful Policy Development – Policies in your department/area should all have the same look and feel – Keep it simple and include only necessary information – Make sure you can adhere to what is in the policy you do not want to increase your audit risk! – Review regularly to make sure the policy is still relevant – Resources available / Communication Training, memos, forms, brochures, etc.. 8

A few examples of Policies your institution should have: – Cost Sharing Policy – Conflict of Interest Policy – Effort Reporting Policy – Intellectual Property Policy – Capital Equipment Policy – Travel Policy – Procurement Policy – Cost Transfer Policy 9

Getting your policy approved: – Navigating the policy approval process at your institution can be tricky! – Many departments might need to be involved based on the topic of the policy OSP HR Legal Procurement Provost Office Controller’s Office 10

Getting your policy approved: – Might help to ask for more authority if the policy is only going to impact sponsored activity – Get all major players in a room together to discuss and review 11

After your policy has been approved: – Set a timeline for issuing your policy Policy effective date is important – Training your audience on the impact of the new policy – Decide where on your website the policy will reside 12

Guidance – Unlike policy it is not mandatory – Seeks to simplify a set of processes with regard to an established habit or practice – Goal is to increase quality and consistency – Guidance is a great way to raise the bar and get the research community to strive for best practices 13

When should you issue “guidance”? – Ideally guidance should be developed in all major areas of compliance even if you do not have a policy – Guidance could become policy in the future – If you are unable to get a policy approved you might consider issuing guidance instead – Faculty and administrators should be trained – Example 14

Why create Standard Operating Procedures (SOP’s)? – Consistency, routine – Improve Productivity – Quality Control, Compliance – Training and cross-training (staff turnover) – Best practices can be established – Collaboration as a department in developing SOP’s can increase morale – Employee evaluations – Help in an audit (internal or external) 15

Standard Operating Procedures…where to begin? 1. Identify - Determine which areas of your work will benefit from a standard operating procedure - Where would it help have consistency? - Where will you see the greatest success? 2. Risk and Controls - Focus on the areas where the risk is high and controls are needed 16

Standard Operating Procedures…where to begin? 3. Collaboration - Determine who is going to take the lead to document each SOP - Brainstorm as a group on the SOP - discuss at least the high level controls needed 4. Development - Work as a team in development with one clear lead - Include an introduction or scope of the procedure - List all tasks and include descriptions of the tasks - Define any necessary terms upfront - Keep it short, without leaving out necessary information or consider breaking into smaller SOP’s - Determine the best format – checklist, word doc, flowchart 17

Standard Operating Procedures…where to begin? 5.Test - Ask a few of the team members to check the SOP when performing actual procedure 6. Notification - Notify necessary people of the new SOP - Give access to SOP document on website or server 7. Training - Provide training on the new SOP 8. Review - Establish process for reviewing SOP (e.g. annually) 18

Questions? Thank you! 19