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NDSU Grant & Contract Accounting
Located: Stop & Go Center 1919 University Dr Website: Main Office Phone #:
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How a proposal becomes an award…
Proposals (includes Proposal, Budget, Work plan, Cost Share, etc.) Proposal Reviewed by SPA (Ag Proposals are also reviewed by Ag Budget) Official Award Contract Approved by SPA PTF and Official Award sent from SPA to GCA GCA Sets up Award Award Information Sheets are ed to PI/Dept Admin
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Award Information Sheet
GCA’s primary function is the financial management of grants and contracts – i.e. billing the sponsors, which means we have continually monitor expenses to make sure they are allowable – it’s our job to review that so sponsor’s don’t come back and question or possibly deny expenditures. Cost Reimbursable – We invoice as expenses post. Advanced Pay – cost reimburseable, but sponsor pays up front and we return unused funds. Scheduled Pay or Fixed Price – sponsor pays up front – we keep unused portion (should be generally less than 20% unused) however if expenses go over amount agreed to get the work done, NDSU is responsible for extra expenses.
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Related Projects – these are simply ‘subprojects’ off the main award…
Related Projects – these are simply ‘subprojects’ off the main award….i.e. NDSU main award PI divides funding with other NDSU faculty members (Co-PIs) and those Co-PIs manage their own funding on subproject. The main PI is responsible for submitting the sponsor’s required progress/technical reports. SUBAWARDS are different – that is when the NDSU PI is going to divide funding with an external agency – i.e. another university or agency.
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Period of Performance 2 CFR§ 200.77 Period of performance.
Period of performance means the time during which the non-Federal entity may incur new obligations to carry out the work authorized under the Federal award. The Federal awarding agency or pass-through entity must include start and end dates of the period of performance in the Federal award (see §§ Information contained in a Federal award paragraph (a)(5) and Requirements for pass-through entities, paragraph (a)(1)(iv)). The PTF may come over with proposed start and end dates, however the official start and end dates are found in the actual contract / agreement that is signed by NDSU and the sponsor – often differs from the PTF. Expenditures should kind of form a bell curve over the life of the grant – spending will most likely start slow at the beginning – increase with the majority of spending in the middle, and at then end, slow down again as the project is finishing up. Would be atypical to have the majority of the spending at the very end – that would be a red flag!
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Direct & Indirect Costs
2 CFR : Direct Costs: (a) General. Direct costs are those costs that can be identified specifically with a particular final cost objective, such as a Federal award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances must be treated consistently as either direct or indirect (F&A) costs. Indirect Costs: Those costs that are not easily allocable to an individual project or benefit more than one source of funding. Ex. office supplies, printer supplies, telecom, postage, The indirect funds that are returned to the college (normally 42%) and then sometimes passed back to the department and/or PI should be used to purchase those supplies that are not normally allowed on grants – office supplies, printing, postage, etc. Those type expenses are only allowed as direct costs if they are specifically listed in the approved budget.
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F&A Rate Descriptions ORGANIZED RESEARCH: Organized Research means the critical and exhaustive investigation or experimentation having for its aim the discovery of new facts and their correct interpretation; the revision of accepted conclusions, theories, or laws, in light of newly discovered facts; or the practical applications of such new or revised conclusions. This category includes all activities specifically organized to produce research outcomes, whether commissioned by an external agency or separately budgeted by the institution. It also includes activities involving the training of individuals in research techniques. INSTRUCTION: Instruction means the teaching and training activities of an institution. Except for research training, this term includes all teaching and training activities, whether they are offered for credits toward a degree or certificate or on a non-credit basis, and whether they are offered through a regular academic session, summer school division, an extension division, or a continuing education division. OTHER SPONSORED ACTIVITY: Other sponsored activities mean programs and projects financed by federal and non-federal agencies and organizations which involve the performance of work other than instruction and organized research. Examples of such programs and projects are health service projects, and community service programs. These categories will dictate which NDSU negotiated rate that is used.
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Facilities & Administration
Location Rate Description* Rate Effective Period On-campus Organized Research 45.0% 7/1/2014 – 6/30/2018 Off-campus 26.0% Instruction 50.5% Other Sponsored Activity Rate 43.2% The RECs are considered off-campus.
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Allocation of Cost Must be allowable Must be allocable
Must be reasonable Must be necessary Must be during the Period of Performance Must be given consistent treatment Must conform to any special limitations/exclusions per the sponsor If costs are benefitting multiple projects, they must be prorated on a reasonable basis not on award ending date and/or funds available Projects are not “buckets” of money to spend down and then move to the next – the expenses must be incurred to benefit/meet the project goals and happen within the period of performance.
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Allocable (Allowable & Applicable)
Major Considerations Incurred solely to advance the work of the agreement Benefits both the agreement and other work of the institution in proportions that can be approximated Necessary to the overall operation of the institution and deemed assignable in part to the agreement **Costs allocable to a project may not be shifted to other agreements to meet deficiencies caused by overdrafts or other fund considerations to avoid restrictions or other reasons of convenience
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Reasonableness Major Considerations
Prudent Person test – act with due prudence Generally recognized as necessary for the purpose of the project Laws, Regulations, NDSU Policies, Sponsor Terms and Conditions Consistent with institutional policies and practices
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Payroll Overload & Overtime Salary – only allowable if included in the approved budget At the end of an award – salaries must be moved to another applicable funding source Retroactive Salary Adjustments (Retros) – must be completed in a timely manner Explanation of Change – required The explanation should reflect an allowable reason for the change – i.e. ‘grant overspent’ is not a valid reason. Payroll expenses should be reflective of actual effort The explanation of change is reviewed on all retro’s – if the reason is not allowable, we may you to inquire further or send back as not approved.
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Travel Foreign Travel – Must be included in approved budget or receive Sponsor approval Domestic Travel – if not in your budget, check with GCA to see if sponsor approval is required Fly America Act (must be an American Carrier) Dates of Travel must be within Period of Performance NDSU Grant Policy 809 Note - Foreign travel has new account codes and is now a separate line on the PI Report. On many commodity awards, travel is more scrutinized – in some cases can not go over at all without sponsor approval.
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Cost Share Types of Cost Share – portion of costs not covered by the sponsor Cash Contributions – represent cash outlay Salary paid by other NDSU (non federal) funds The value of salary cost share = % Effort x (NDSU Salary + Fringe Benefits) for the applicable pay periods Waived Indirect Costs Tuition Waivers Supplies, etc. In-kind Contributions Non-Employee volunteer labor Meeting facilities Performance of services at a reduced cost Salary paid by other NDSU funds and waived indirects are probably the most common cost share or Match resources. Salary cost share will be reflected on the PAC / Effort Reports. GCA will work with Pis and/or administrative staff to calculate cost share percentage and what time frame to spread the cost share.
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Salary Cost Share Voluntary Cost Share
Contribution to a Sponsored project but not required as a condition of obtaining funding Committed (if it’s in the budget it’s committed): cost share must be setup, tracked and reported Uncommitted: Report by “writing in” the award/project # and the % of effort on the PAC, certify and submit to GCA Mandatory Committed Cost Share Contribution to a Sponsored project that is a conditional requirement of receiving the award
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Modifications Pre-award Spending
Pre-award spending may be requested through SPA. These expenses must still following all the allowability tests: allowable, reasonable, allocable and necessary SPA will Need Documentation of sponsor’s intent to fund Statement for Department Chair stating they will cover all costs if award doesn’t get funded Useful to avoid retros and/or you know you have supplies that need to be purchased immediately (i.e. field work starting)
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Modifications Grant Rebudgeting Requests Send request to applicable GCA Officer (helpful to answer these 5 questions) What budget categories are going to be increased? What budget categories are going to be decreased? How will the rebudget help meet the project goals? For those categories decreased how will the decrease not impact meeting the project goals? Will there be a change in scope? If no-sponsor approval is needed the GCA officer will assist in getting the re-budget posted If sponsor approval is needed – the GCA officer will forward your re-budget request to SPA. We have template spreadsheets available that will help with the first two questions above.
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Modifications No-cost Extension Complete the No-Cost Time Extension Request form on the SPA website and to SPA Note: A no-cost extension should not be requested just to spend down remaining funds Keep in mind, some sponsors have a pre-determined amount of time in advance of the end date in which they will review and/or grant extensions. i.e. ‘no later than 1 month prior to the end date’ Disposition of Grants The disposition of grant form should be completed when there is a change in PI and when a PI is leaving NDSU and has active grants Disposition of Grant – is the award following the departing faculty or will it be reassigned to another NDSU faculty or will sponsor cancel the award.
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Reports & Queries Finance: Grants Workcenter HRMS: PI Report
Detailed Transaction Report (recommended over Budget Transaction Detail – provides higher level of detail) Award or Project Summary Report Budget Overview HRMS: HE Salary Distribution Report
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Budget Overview will give the most up-to-date balance (current) – the other reports (PI, Detail Transaction,e tc) are all a one day lag. Use this link to find the assigned GCA – type in project # and click ‘Project Team’ link
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PI Report *REMEMBER* The PI Report must now be retrieved from REPORT MANAGER
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PI Report (bottom half)
*REMEMBER* The PI Report must now be retrieved from REPORT MANAGER
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Detail Transaction Report
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Award or Project Summary Report
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Budget Overview
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Salary Distribution Report (HRMS)
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Audit Red Flags Unauthorized, Inappropriate and/or Unallowable Charges
Overruns or large unexpended balances Assignment of costs based on fund availability or project expiration Cost Transfers Must be done on a timely basis – no later than 90 days after incurrence and before the final financial report is due Moving an expense from one grant fund to another grant fund A large # of cost transfers might suggest lack of internal controls – especially at the end of the grant Inadequate documentation Effort Certification Must be based on how time was actually spent, not how salary and wage costs were distributed, although the two are generally related Late PAC’s Equipment purchases near the end of project Not obtaining proper Prior Approvals
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Audit Red Flags Failure to justify Sole-source purchasing
Late Reporting Overvaluing Third party in-kind contributions Insufficient documentation Not Immediately communicating significant developments Incomplete property records Untimely or lack of periodic inventory Not applying “applicable credits” to allowable cost principals
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Grant vs. Gift Restricted vs. Unrestricted Gifts
NDSU Policy 803 Grant Written agreement with specific use of funds beyond a broad programmatic designation, or Technical reports are required, or Financial reports are required, or The work being done has potential for intellectual property (i.e. patents & copyrights) Gift – Restricted Restricted to a program or more specific (79XXX fund) Gift – Unrestricted General use (local fund) Senior Design/Capstone Projects Setup as a special project in GCA
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Policies, Guidelines, Resources
NDSU Policies & Procedures ND Century Code SBHE/NDUS Policies & Procedures OMB Fiscal & Administrative Policy NDSU Policies - Section 8 OMB Uniform Guidance 2 CFR 200 Sponsor Policies & Procedures Sponsor Terms & Conditions Special Terms & Conditions added to the award document NCURA YouTube Learning Management System – NCURA Toolbox for Research Administrators RCA Update s Sponsored Programs Administration (SPA) Grant & Contract Accounting (GCA)
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Grant & Contract Accounting (GCA)
Name Phone Portfolio Includes: Ann Young 1-8356 Director Grant and Contract Accounting NSF, DHHS, Dept of Education, Challenge Grants Beth Astrup 1-8393 Dept of Interior, Dept of Defense, NASA, CNCS Teresa Driscoll 1-5133 ND Dept of Commerce, Industries (Private & Non-Profit) Laura Lutkemeier 1-9802 State Agencies & Commodity Groups, Effort Reporting David Munro 1-1045 DOT, Public Instruction, Non-Federal CNCS, Foundations, SEFA, Recharge Centers Sara Ogundolani 1-5939 USDA (NIFA, ARS, APHIS, AMS, NRCS) & USDA Flow-Through Mary Freeman 1-8357 Restricted Gifts, Grant Auditing, Administrative Support
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Sponsored Programs Administration (SPA)
Name Phone Responsibilities Include: Val Kettner 1-9608 Associate VP, SPA Proposals certifications signatory, external contract negotiation Amy Scott 1-8976 Assistant Director, SPA Signatory for grant proposals and awards; assistance with pre-award and non-financial post-award administration Jill Mackenzie 1-5494 Signatory for grant proposals and awards; grant award negotiation, backup proposal review Cindy Eleson 1-5259 Budget and proposal preparation, NSF Fastlane, electronic proposal submission Wayne Wermager 1-8898 Budget and proposal preparation, assistance with non-financial post-award administration Shelly Sandstrom 1-7258 Processing of grant awards, assistance with non-financial award administration Faye Klein 1-8045 Front desk, General administrative questions
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Questions???
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