1. Overview Post-award Issues for the
Pre-award and Departmental Administrators
What does this mean for you,
for your institution?

2. Overview Fine line between pre and post award
Handled within one office or two
Thorough knowledge is needed from proposal preparation to closeout

3. Overview To more effectively and efficiently manage research
Discussion on a proactive approach to working together

4. Outcomes Impact that pre and post award has on the other
Impact of the proposal and negotiation process on the PI
Departmental administrators will understand the needs of pre award administrator (and visa versa)

5. The Research Cycle
Proposal
Award
Performance
Closeout
Audit

6. Award Instruments
Grant
Contract
Cooperative Agreement

7. Definition: Grant
Purpose is to transfer money, property, services or anything of value to recipient in order to accomplish a public purpose
No substantial involvement anticipated between government and recipient

8. Definition: Contract
Purpose is to acquire property or services for direct benefit or use of the federal government
Very restrictive. No expectation of cost sharing

9. Definition: Cooperative Agreement
Purpose is to transfer money, property, services or anything of value to recipient in order to accomplish a public purpose
Substantial involvement anticipated between government and recipient

10. Principal Investigator
Prep of programmatic proposal
Development of project budget
Monitor programmatic and financial performance
Adhere to terms and conditions of award

11. Principal Investigator
Closeout: Final progress report, invention statement.
Financial responsibility and audit

12. Departmental Administrator
Assists and advises the PI in preparation of proposal, in accordance with sponsor terms and conditions, applicable regulations, institutional policies

13. Departmental Administrator
Assists PI in compliance with award terms and conditions, regulations, institutional policies

14. Departmental Administrator
Monitors expenditures of award funds, obtains necessary authorized signatures

15. Departmental Administrator
Coordinates with central offices on reporting

16. Departmental Administrator
Assists central administration with closeout and audit activities

17. Sponsored Programs Office
Review of Proposals for Regulatory and Policy Issues
Ensure Proper Sign-offs
Negotiate Agreements
Approve Certain Transactions

18. Review of Proposals
Review of RFP, BAA, Program Announcement for terms that may be problematic
What is PI promising that department and post-award staff have to comply with?

19. Ensure Proper Sign-offs
Who is Authorized to Approve Proposals/Commit resources?
Who Can be PI?
Acceptance of Risk (Overruns, Cost Sharing, Under-recovery of F&A)

20. Negotiate Agreements
Does contract have requirements that are “non-standard”
Who will non-standard terms impact?
Will they accept the terms?

21. Negotiate Agreements Examples of non-standard requirements:
Monthly progress reports
Quarterly invoices
Sponsor retains title to equipment after period of performance

22. Approve Transactions
OSP should notify post-award administrators of award terms in advance of spending.
For example, equipment purchases, travel approval, other “special” requirements of sponsor.

23. Grant/Contract Acctg
Review accounting transactions based on allowability criteria, terms and conditions, and agency guidelines.
Review such transactions for compliance with University guidelines.

24. Grant/Contract Acctg Review for proper signatures
Review for fund availability
Prepare billings and financial reports
Collect cash

25. Grant/Contract Acctg Maintain effort reporting system
Advise PI and departmental administrators on financial matters
Coordinate A-133 and other audits

26. Shared Responsibilities
Stewardship and accountability
Effective management of public funds

27. Communication Challenges
Sponsor/Institutional Policies
Face-to-Face Meetings
Websites with up to date information
Electronic tools

28. Getting Stakeholders on the Same Page
Transmit a copy of award document
Inform key staff of award terms and conditions
Ensure key staff know and understand responsibilities
Dialogue during performance period

29. Time is of the Essence
Identify problems early and resolve problems as soon as possible and with as few parties involved as necessary to reach a solution.
Attempt to resolve problems promptly
Make sure all involved parties understand the issue
Know when to involve the sponsors

30. Pre-Award/Post-Award Offices: A Team Effort
Understanding each other’s roles & responsibilities
Conduct joint staff meetings
Conduct joint discussions with departmental staff
Project a team approach to resolve issues

31. Improving Communication
Early review of program announcements, solicitations, RFP, etc

32. Improving Communication
Identification of unusual sponsor requirements, e.g. reporting

33. Improving Communication
Discussion of problematic terms prior to proposal submission

34. Improving Communication
Communications with sponsor, avoiding “informal” agreements

35. Issues in Proposals Office Supplies Computers
Cost Accounting Standards
Office Supplies
Computers
General Purpose Equipment
Local Telephone

36. Issues in Proposals 5. Dues and Subscriptions 6. Unallowable Cost
7. Know your institution’s policies

37. Direct Charging of Administrative Costs
OMB Guidance on A-21 Revision to section F. 6. (b) (July 1993)
“In developing the departmental administration cost pool, special care should be exercised to ensure that costs incurred for the same purpose in like circumstances are treated consistently as either direct or F&A costs ...”

38. Direct Charging of Administrative Costs
OMB:
“Direct charging ... may be appropriate where a major project or activity explicitly budgets for administrative or clerical services”

39. Direct Charging of Administrative Costs
Do we explicitly budget for these costs in the research proposal?
Does the proposal include a written justification (why costs are necessary for project performance)
Is this a “major project” as defined in A-21 and Exhibit C?

40. Direct Charging of Administrative Costs
Are administrative and clerical costs approved by the Sponsor?
Is there a record of this for audit?
Effort report must reflect actual time spent –consistent with approved proposal budget

41. Proposal Budgets Required by Sponsor or volunteered by investigator
Cost Sharing
Required by Sponsor or volunteered by investigator
University commitment
Impact of F&A rate

42. Effort Reporting Definition:
A method of certifying time spent on a research grant, and justifying salary expense charged to sponsor

43. Effort Reporting Regulation
OMB Circular A-21, Section J.10 “Compensation for personal services”
J.10.b. Payroll Distribution requirements

44. Effort Reporting Direct charged? Cost Shared?
What effort is committed in the
proposal?
Direct charged?
Cost Shared?
Commitments must be tracked

45. Effort Reporting Issues
Multiple sources of pay (e.g., faculty practice plan)
NIH salary cap
Summer salaries
Cost transfers not incorporated into certification

46. Effort Reporting
For personnel whose salaries are charged (or cost-shared) to research grants and contracts
Effort should be certified by “responsible persons with suitable means of verification that the work was performed”

47. Effort Reporting
Per A-21: System will provide for independent internal evaluations to ensure compliance
How does this happen at your institution?

48. Issues in Proposals Proposing the correct rate
Facilities and Administrative Rate
Proposing the correct rate
Research, instruction, other sponsored activity

49. Issues in Proposals 3. Regular rate or special location rate
4. On Campus or Off Campus Rate

50. Program Income Definition (A-110)
Gross income earned by the recipient that is directly generated by a supported activity or earned as a result of the award

51. Program Income 1) Add to Award 2) Use to Fund non-Federal Share
Will Award Generate Program Income?
What Do We Do With Income?
1) Add to Award
2) Use to Fund non-Federal Share
3) Deduct from Total Project

52. Subcontractors Scope of work Budget Institutional commitment (OSP)
Proposals including subcontracts should include:
Scope of work
Budget
Institutional commitment (OSP)

53. Subcontractors Is this a Subcontract or Consultant relationship?
Independent line of inquiry or providing service or expertise?
Difference in F&A treatment
Difference in ownership of IP

54. Subcontractors Approval of Subcontract Invoices
PI should judge whether progress is satisfactory
Dept Administrator should determine whether subs costs are appropriate, within the period of performance

55. Who can perform the audit Audit timetable Record retention
Issues in Proposals
Audit Requirements
Who can perform the audit
Audit timetable
Record retention
Notification requirement

56. Acceptance and Assignment of Financial Risk
Institutions authorized recipients
Document and report project costs
Institutional policies for cost overruns on project

57. Payment Terms Advance Payments Cost Reimbursement Payments
Progress Payments based on milestone deliverables

58. Payment Terms
Frequency
Invoices and backup documentation

59. Payment Methods
Letter of Credit Draws
Electronic Fund Transfer
Checks

60. Reporting Requirements
Contracts with unusual Reporting Requirements may be a problem
Reporting of labor hours worked
Detailed expenditure reporting
Monthly Progress Report

61. Reporting Requirements
Pre-Award Must Communicate the Types of Reports, Frequency of Reporting, Due Dates
Contract reporting requirements more onerous than grants
May be penalties for late reports

62. Reporting Requirements
Types of Reports
Technical/Progress (PI)
Patent/Invention (PI)
Fiscal (Sponsored Accounting)
Property (Asset Accounting)

63. Reporting Requirements
Pre-award office may be tasked with pursuing late reports
Correct report distribution info can minimize late reports
Timely reporting requires coordination

64. Performance Issues Approval of project expenditures
Documentation of project expenditures

65. Closeout Responsibilities
Reaching the termination date of a project does not signal the end of our responsibilities
Institutions have sponsor requirements to fulfill before we can closeout the award

66. Closeout Responsibilities Financial Accounting
Costs must be allowable, allocable, reasonable and consistent with the terms of the agreement
Good project management over the life of the award will help to eliminate any problems after the award has ended

67. Closeout Responsibilities Financial Accounting
Pre-Award must communicate the with the Dept/PI
Is this a Fixed Price agreement or Cost Reimbursement
What is the process for an extension? Prior approval needed?
Carry-forward of funds allowed?

68. Closeout Responsibilities Financial Accounting
Departmental Administrator and PI must ensure that all costs are necessary for the performance of the project, incurred within the period of performance and charged to the project within the specified period (e.g. within 90 days of termination).

69. Closeout Responsibilities Reporting
Financial Reports: Have all project expenditures been posted?
Technical Reports (PI): Submitted timely (or at all)? Appropriate and complete information (Award #, PI name, title, etc.)? Proper report distribution?

70. Closeout Responsibilities Reporting
Invention Reports: Have reports been filed, using appropriate forms (see Campbell Plastics)
Property Reports: Who owns equipment, what is disposition, when was equipment purchased?

71. Audit Responsibilities
Anticipate the project will be audited
Audits often take place after the project is completed and several years after the expenditures were incurred

72. Audit Responsibilities OMB A-110
“The Federal awarding agency…or any of their duly authorized representatives, have the right of timely and unrestricted access to any books, documents, papers, or other records of recipients that are pertinent to the awards.”

73. Audit Responsibilities OMB A-110
“This right also includes timely and reasonable access to a recipient's personnel for the purpose of interview and discussion related to such documents.”

74. Audit Responsibilities
If records are requested and interviews are conducted for an audit which takes place several years after expenditures were incurred, will we be prepared to justify and support that the expenses are direct project costs?

75. Audit Responsibilities
Documentation is the key to being prepared for an audit
Are project effort reports signed?
Is cost sharing documented?
Procurement expenditures properly documented?

76. Audit Responsibilities
Record Retention
Financial records, supporting documents, statistical records, and all other records pertinent to an award shall be retained for a period of three years from the date of submission of the final expenditure report (A-110)

77. Audit Responsibilities
Question:
When is the best time to prepare for an audit?
Answer:
Now (and throughout the project)!