1. The Gold Standard: Sharing Tips of the Trade and Best Practices
2017 AOA Conference
San Diego, California
Audience Poll – Who has pre and post award processes combined? Who has pre and post award processes separated?

2. Objectives
Pre and Post Award Process -- Discuss the pros and cons of combined vs. separate offices
Internal Controls – Discuss what constitutes a good internal control, and be able to identify effective key controls that can be used for the R&D program
Discuss Common Issues, Trends, Tips and Best Practices

3. Pre & Post Award Process -- Combined or Separate?
“One man’s ways may be as good as another’s,
but we all like our own best.”
Audience Poll – Who has pre and post award processes combined? Who has pre and post award processes separated?

4. Roles of the Pre Award and Post Award Process
Pre Award Roles
Post Award Roles
Roles/Responsibilities that may fall in both
Compliance
Reporting
Subrecipients
CLA has seen pre and post award processes and responsibilities done different ways. (Briefly discuss different roles within each group)
What we are going to focus on this morning, is what we have seen/observed in regards to universities that have combined pre and post award processes and those that have separated pre and post award processes.

5. “Working together works.”
AOA University #1
“Working together works.”

6. Background: AOA University #1 Post-Award Statistics
$106M in awards
$104M in expenditures
Experienced expenditure growth of 16.5% annually over the past five years
Staff has not increased significantly during that time frame
1 Assoc Dir; 4 Sr. Research Administrators; 2 Grant Coordinators

7. Background: AOA University #1 Post-Award History
Co-located with the pre-award office in before combining with pre-award in 7 months later as Sponsored Programs
Oversight under Vice President for Research
Many adjustment issues after combination

8. Advantages of a Combined Office
One Vice President to provide vision and leadership
One Director to manage office
Unification of policy, procedure, and process
Better staff understanding of cradle to grave business process
Team work is easier

9. Disadvantages to a Combined Office
Potential audit issues – no separation of duties
Potential for weak or dysfunctional relationship with other divisions at university
if under Research, then potential relationship issues with Finance or vice versa
Sometimes there is little understanding by your division leadership for aspects of your workload that may be more familiar to another division (try explaining F&A proposal development to a sociologist)
Training a professor on Uniform Guidance Requirements

10. Culture at AOA University #1
New mission and focus for institution
Workload changes
Technology
External and internal environmental awareness
Experience with non-standard research issues
Reputation of the university

11. Culture – Centralization vs. Decentralization Considerations
University Systems
Use to your advantage
Risk Management and Office Role
Distribution of Activities
Time/effort monitoring
Expenditure monitoring
Other post award activities

12. Communication
“Seldom, very seldom, does complete truth belong to any human disclosure; seldom can it happen that something is not a little disguised, or a little mistaken.”

13. Communication in a Combined Office
Weekly meetings between Associate Vice President for Research and Executive Director
Weekly individual meetings with Executive Director and Associate Directors of pre and post award to discuss issues
Monthly combined meetings of Executive Director and both Associate Directors
Monthly staff meetings
Regular meetings with Finance Division staff

14. Lessons Learned at AOA University #1
“We have all a better guide in ourselves, if we would attend to it, than any other person can be.”

15. Lessons Learned Quantify Create policies and procedures
Write it down and document
Business process redesign
Quality
Network
COMMUNICATE

16. The experience of a separate post-award office
AOA University #2
The experience of a separate post-award office

17. AOA University #2 Pre and Post Award Structure
AOA University #2 has separate Pre and Post Award Offices
Pre-Award and Contracts combined – Report to VP for Research
Post Award – Report to VP for Finance
Contracts eventually combined with Pre-Award
Previously co-located with Post Award

18. Background: AOA University #2 Statistics
Carnegie Foundation designation
Very High Research Activity
$145M in Awards
$149M in Expenditures
2,800 Active Awards
Cognizant Agency is DHHS
Major Sponsors are NSF, USDA, HHS
No Audit Findings

19. Duties of Post Award Admin
Award Set-up in FIS – Banner
Invoicing Agencies
Accounting/Monitoring
Budget Changes
No Cost Extensions
Reporting/Closeout
High Risk Expenditure Approvals
Audit Coordination
Cost Share
Subcontract Admin
Electronic Filing System
Effort Reporting
Fellowship Admin
Training Campus Department Staff

20. Advantages of Separate Offices
Commended by Internal Audit
Allows for Separation of Duties
Maintain Focused Missions
Post Award Reports to Finance VP
Understanding of Financial Issues

21. Disadvantages of Separate Offices
No Flexibility for Exceptions
Unique Circumstances
Post-Award very focused on Regulations
Pre-Award Doesn’t Understand Post-Award Issues with Invoicing and Budgets
Communication Breaks Down or Non-Existent
Conflicting Policies and Procedures
Hard to Establish “Seamless Operation” with Faculty

22. Culture – Centralization vs. Decentralization at AOA University #2

23. Business Centers at AOA University #2
Central Accounting Office
Pay Bills up to $500,000; Reimbursements
Process HR Actions
Review Proposal Budgets
Effort Report Monitoring
Reports to Finance and Administration
Ensures Compliance
Provides Separation of Duties for Colleges

24. Business Centers at AOA University #2
Train Staff
Grant Accountants come to OPAA for Training
Immersion in OPAA (Central Admin functions)
Train for 4-6 months
Include in staff meetings/social functions when return to Business Center
Grant Accountant from OPAA will Rotate to Business Center to Establish Compliance Culture
OPAA (Office of Post Award Administration)

25. Communication Between Separate Pre-Award and Post-Award Offices
Close Proximity of Offices
Co-locate if you can
Meet Weekly to Discuss Issues
Develop Joint Policies and Procedures
Develop Joint Communications to Campus
Develop and Present Training Jointly
Review Websites for Conflicting Information

26. Communication Between Separate Pre-Award and Post-Award Offices
Release Data Jointly
AOA University #2 offices work together for award and expenditure data releases
Host Joint “Meet and Greets” for Campus
Create Opportunities for Staff
Get to know each other
Mentor each other in procedures
Encourage team building

27. Communication in General
Ad hoc work or issue groups
AOA University #2 utilizes for policy implementation
Formal university committees
Informal networking within university
AOA University #2 meets monthly with campus University Research Administrators
External networks and groups

28. AOA University #2 Story - Today
The University has now combined pre/post award processes
The transition was difficult due to lack of communication and buy-in from staff.
Maintained segregation of duties – processes pretty much the same. They now report to the same VP.
Definitely recommend combining Pre/Post Awards as long as it is set up right.
Communication is key.

29. Humboldt State University Sponsored Program Foundation
“Our Model”

30. Humboldt State University – Our Model
History
Previously a standalone auxiliary doing their own accounting/payroll focused mainly on post award
Contracted with campus to do accounting/payroll 6 years ago. Remaining grant analysts became state employees and reimbursed the state
Established a pre-award office with two people
Everyone reported to the Director of the Foundation

31. Humboldt State University – Our Model
Things that Work
Combined pre and post works great
Utilizing campus accounting allows us to focus on our expertise
A Compliance Officer position keeps everyone on track
Challenges
Providing great customer service as volume increases
Not rushing to hire on revenue spikes
Locating qualified employees
Tension between campus and auxiliary over excess money

32. What has your experience been?
Audience Feedback
What has your experience been?

33. Considerations

34. Considerations and Other Comments
Size and planned growth of the program
Culture
Resources
Increased funding (# of Contracts, compliance, reporting)
Team vs. autonomy - Culture is a good work environment – size could make it harder to work together if separate

35. Questions

36. Internal Controls

37. Internal Control Needs for Research Administration
General Internal Controls
Communication of policies, procedures, and funding agency requirements
Segregation of duties between initiating, authorizing, and recording
Monitoring activities for all funds passed to subrecipients

38. What is the Risk? Fraud in Higher Education
Failure to Comply with Federal Requirements

39. How Fraud Happens PRESSURE Opportunity Rationalization
Emergency/Favors
Financial Stress/Greed
Career Advancement
PRESSURE
No one is watching
Inadequate Segregation of Duties
Lack of Management Review
Opportunity
The requirements are unreasonable and unnecessary
Money “belongs” to them for research
Results would have been similar if the research was completed
Rationalization

40. Procurement Fraud in Research
Bid Rigging
Bidders agree to manipulate the process
Rotation of bid awards
Sharing of bids with bidders
Bribery
Vendors provide kickbacks in order to be awarded contracts
Gifts, money, trips
Conflicts of Interest
Hiring relatives to work on grant funded projects
Awarding contracts to related parties without disclosure

41. Procurement Fraud Continued
Phantom Vendors
Set up of fictitious vendors
Payments diverted for goods and services not received
P-Card Misuse
Employees pay for personal items with P-Card
Splitting
Employees divide the purchase into smaller components to avoid approval thresholds

42. Asset Misappropriation in Research
Theft of gift cards
Theft of computer equipment
Medical supplies sold for cash

43. Overstatement of Credentials/Results
False Information in Grant Applications
Employee Overstatement of Degree
Hacking of Results Data to Show Different Results

44. Some Signs You Could Have a Problem
Procurement
Initial contract has multiple change orders
Purchase orders created on evenings and weekends
Multiple vendors with the same address
Asset Misappropriation
Poor recordkeeping for gift cards/personal incentives
Poor recordkeeping for small portable computer electronics
Unusually high supply costs compared to research performed
Overstatement of Credentials/Results
Retracted journal articles
Background checks do not support degrees claimed

45. Prevention before Detection
Communicate policies and procedures with employees
Perform technical review of proposals
Ensure management review of grant reporting – financial and performance
Monitor subrecipients – more than obtaining audit reports
Analyze your data

46. Higher Education Communication Ideas
The University of Central Florida hosted a screening of "Catch Me If You Can," about conman Frank Abagnale Jr.
the ACFE Purdue University Chapter held an anti-fraud seminar.
Utica College waived application fees for their online fraud and financial crime degree programs, as well as had a complimentary webinar centered on identity theft and money laundering.

47. Data Analysis Multiple purchases to single vendor
Multiple invoices for same item
Even dollar amounts
Purchases just under approval thresholds
Purchases made on evenings and weekends

48. Questions

49. Common Issues, Trends, Tips and Best Practices

50. Best Practices and Tips
COMMUNICATION is key
If you are looking to combine Pre/Post Award processes, create a team to be part of the process for the project. The team should consist of the Pre Award Officer (obtain the grant), Contracts Officer (grant reviewer-for consistency), Accounting (responsible for Post Award accounting/compliance)
Property management runs weekly queries to see what was purchased and coded as equipment. They DO NOT wait for people to tell them, as they know this may or may not happen. Be proactive.

51. Best Practices and Tips
Pre and Post Award have different expertise, work closely together to provide the best service so the PIs can do their work.
Every grant gets reviewed by a Senior Accountant once per quarter. This allows the ability to catch errors and correct them along the way.
Spread the work as best as possible so no one individual is overburdened - especially during quarterly federal reporting.

52. Questions

53. Steve Karp Nancy Jones, CPA Caroline Wright, CPA Director
Interim Dean of Research
Humboldt State University
1 Harpst Street
Arcata, CA
Nancy Jones, CPA
Director
CliftonLarsonAllen LLP
3000 Northup Way, Suite 200
Bellevue, WA
Caroline Wright, CPA
601 West Riverside, Suite 700
Spokane, WA