MRAM Monthly Research Administration Meeting NOVEMBER 12, 2015 UW TOWER AUDITORIUM NEXT MRAM DECEMBER 10, 2015 UW TOWER AUDITORIUM TOPICPRESENTERCONTACTMIN Effort Reporting Update Michael Anthony Executive Director, Management Accounting & Analysis Project Certification Michael Anthony Executive Director, Management Accounting & Analysis IRB Fee for Industry-Funded & Industry-Initiated Sponsored Studies Jason Malone Assistant Director, Regulatory Affairs Human Subjects Division Compliance Corner Ted Mordhorst Director, Research Compliance & Operations CORE Course Update Mara Rivet Learning, Outreach & Communications OSP

Effort Reporting Update FECs and GCCRs MRAM - November 12, 2015 Michael Anthony Management Accounting & Analysis University of Washington

 Confirm changes, e.g., OSETS, Cost Share Commitment Adjustments, have processed and appear on the FEC before having faculty certify.  Insufficient Funds – Make sure the predefined comment (“Non- federal grant(s) approved to be used for cost share…”) is checked AND the ‘contributing budget(s) and percent contribution(s) are reflected in the “Additional Comments” section.  Net ID – Certify others – Make sure the individual is eligible for this role (Chair, Dean, Director). FEC Certifications University of Washington Management Accounting & Analysis

 Salary Cap (monthly rate)  Issue for faculty not paid for full FEC cycle, e.g., 2 summer months during spring/summer cycle  FEC can have the appearance there is no salary cap issue when 2 months summer salary is spread over 3 months (summer quarter) which is combined with the Spring quarter  Not OK to be over the cap and charge nothing but grants Salary Cap Issues University of WashingtonManagement Accounting & Analysis

 Pre-pay / Pre-work  Salary charged must reasonably reflect work of each pay period.  Cannot misrepresent actual effort for the period.  Example - Overcharging grant (undercharging department funds) during AY so department can pay summer salary from savings. Other Issues University of WashingtonManagement Accounting & Analysis

 Issue with fiscal close  When OSETs or other salary transactions occurred during month 25 it resulted in the GCCR report generator resetting for some departments/PUCs  Appeared as though GCCR reports were not downloaded after month 24  If you haven’t, please do and we will stop contacting you GCCR Issue University of WashingtonManagement Accounting & Analysis

Project Certification MRAM - November 12, 2015 Michael Anthony Management Accounting & Analysis University of Washington

A demonstration with 4 universities and 2 federal agencies to demonstrate a new alternative method for reporting time and effort information on federally sponsored research grants FDP Initiative Project Certification University of WashingtonManagement Accounting & Analysis

 An alternative to Effort Certification  Generally positive response from university communities although some expressed they will not change current procedures  Other institutions encouraged to evaluate to determine if it is a viable option for them FDP Initiative Project Certification University of WashingtonManagement Accounting & Analysis

 Alternative to Effort Certification  Similar to the current GCCR process  All individuals with direct salary charges and/or cost share commitments to a sponsored project(s) would need to be included  One certification per project would cover all individuals  Frequency TBD (beta sites doing this on a monthly basis) Project Certification University of WashingtonManagement Accounting & Analysis

 Generally positive response from the Federal government  Several audits of the beta site universities did raise some concerns primarily centered around internal controls Project Certification University of WashingtonManagement Accounting & Analysis

 NSF – OIG concluded  Need to strengthen internal controls to ensure labor charges to NSF awards are adequately supported  Found problems with 21 of 180 transactions sampled – Not certified in a timely manner, posting errors, missing recertifications due to OSETs  Need to strengthen its IT controls to protect payroll information Audit Results George Mason University University of WashingtonManagement Accounting & Analysis

 NSF – OIG concluded  System "generally provided accountability over federal funds"  Did not always comply with policies for payroll transactions under the effort reporting process as well as payroll certification pilot."  Issue with the security of Banner (payroll IT program)  Of 112 transactions processed under the pilot, OIG found two had problems "related to changing salary and wage distributions."  None were identified as late, and no other problems were noted. Audit Results Michigan Technological University University of WashingtonManagement Accounting & Analysis

 We like the concept (individual championing the FDP initiative former UW Controller)  Similar to GCCR process but lacking many features of eFECS (auto salary cap calculation, cost share commitments, etc.)  Presently do not have IT resources available to devote to a conversion (HR/P, new Financial System) What is our Perspective? University of WashingtonManagement Accounting & Analysis

 Plan to assess the pros/cons of incorporating the current faculty effort reporting (FEC) and non-faculty (GCCR) processes with project based payroll certification  Work with campus units to understand their preferences, concerns, suggestions  Keep tabs on what is happening at beta sites as well as any other institutions adopting project certification What are our Next Steps? University of WashingtonManagement Accounting & Analysis

Any volunteers here today!! What are our Next Steps? University of WashingtonManagement Accounting & Analysis

HSD Administrative Fee MRAM - November 12, 2015 Jason Malone Human Subjects Division University of Washington

 A one-time $ fee to help cover HSD’s costs for fulfilling mandatory regulatory and administrative responsibilities.  It applies to research with an indirect cost rate that does not cover those costs. What is it? University of Washington Human Subjects Division

 The fee applies only to studies that are both:  Industry initiated AND;  Industry sponsored Applicability University of WashingtonHuman Subjects Division

 For studies that go through Clinical Research Budget and Billing (CRBB), the fee is automatically included in the study budget.  For studies that are not using UW clinical services and don’t go through CRBB, the Office of Sponsored Programs (OSP) notes the fee in the Funding Action. How It Works University of Washington Human Subjects Division

 Indirect costs are charged in connection with the fee.  HSD does not send an invoice for the fee.  The fee is automatically paid to HSD by Grant and Contract Accounting (GCA) when the UW receives initial payment from the sponsor. How it works University of Washington Human Subjects Division

 Guidance has been posted to the HSD website:  Contact the HSD IRB Reliance Administrator at: Resources/Questions University of WashingtonHuman Subjects Division

Fiscal Compliance Corner Recent Happenings, etc. MRAM Nov 2015 Ted Mordhorst Director Compliance and Operations Research Accounting & Analysis

Audit News NSF Audit Covers ALL NSF Awards 4/1/10 – 3/31/13 Preliminary Findings:

NSF Data Analytics Audit  Salaries charged in excess of the 2 month rule  Equipment purchased near the award expiration 18 items  Materials and supplies purchased near the award expiration 5 items  Unallocable tavel transactions

NSF Data Analytics Audit  Purchase card transactions without vendor receipt  Unreasonable or unallowable expenses  Purchases more than 90 days prior to the award effective date  meal expenses not necessary or reasonable  Travel that occurred after award expiration

NSF Data Analytics Audit  Auditor Recommendations:  Strengthen the administrative and management controls and processes  Implement university-wide procedures to ensure that all departments are monitoring the allocation of costs charged to NSF awards

NSF Data Analytics Audit  Auditor Recommendations:  Strengthen internal controls and processes over allocating expenses for equipment and supplies to sponsored funding sources.  Require documentation of the methodology used to allocate expenses to sponsored projects, as well as a justification for how the methodology was determined.

Final thought  Audits are increasingly looking at factors related to internal controls  Expense documentation must be maintained and demonstrate reasonableness, necessary and allocability  Expenses during the last 90 days of the award are most often questioned

Final thought  Both in the UG and in the audit there is an increased emphasis on “necessary”, “essential” and “integral” to define when a cost is reasonable.  It behooves us to think in these terms when processing transactions

Other Compliance Happenings  Research Terms and Conditions (RTC)  Developed by the Federal Demonstration Partnership (FDP)  11 federal agencies participating  Open for comments through 12/14/15

Research Terms & Conditions  Somewhat confusing  We will submit comments  Will have agency specific deviations  Incorporated into awards sometime in the spring?  Will share more as this progresses

QUESTIONS?

CORE is a collaborative effort to provide free, high quality, cohesive training on research administration and compliance to UW researchers and research administrators. UPCOMING COURSES IN RESEARCH ADMINISTRATION Nov 16ORIS 103 – SAGE Budget Nov 17GCA 203 – Preparing for an Audit Nov 17ORIS 102 – SAGE: Creating NIH Proposals in Grant Runner Nov 18MAA 231 – Salary Limitations - Salary Cap Nov 24ORIS 101 – SAGE: Creating and Submitting eGC1's Dec 02GCA 202 – Direct Billing of F&A Type Costs Dec 03ORIS 103 – SAGE Budget To see a full list of courses and to register, visit Dec 09MAA 225 – Using the Tools: Calculators, Worksheets and Reports Dec 10ORIS 102 – SAGE: Creating NIH Proposals in Grant Runner