1. Research Administration Forum Grants and Contracts Administration
June 11, 2019

2. AGENDA National Science Foundation (NSF) Virtual Site Visit Debrief
“Go Tigers”
AGENDA
National Science Foundation (NSF) Virtual Site Visit Debrief
2019 Annual Single Audit
HHS/NIH Salary Cap
2016 IRS Letter Ruling–Employee vs. Non-Employee Stipend Payments
University Sponsored Compliance Updates:
Sponsored Compensation Verification Reports – Gina Cofield
Cost Transfer Metrics and Improvements – Sarah Balas

3. NSF Virtual Site Visit
Major Areas of Focus included:
Personnel/Payroll/Sponsored Compensation
Communication of Terms and Conditions
Subawards and Subrecipient Monitoring
Property and Equipment

4. NSF Virtual Site Visit (Continued)
Opportunity for improvement:
Personnel/Payroll/Sponsored Compensation
Lack of policy/procedure documentation for personnel to be paid on sponsored awards, as well as how, when and why changes are to be made during the course of a project.
Non-exempt employees are not able to assign the number of hours worked during each pay period to the appropriate project or chartfield string where the work was performed.

5. 2019 Annual Single Audit
Preliminary sampling – Internal audit requests
HHS/NIH Cap Review and Reminder:
Effective January 7, 2018
$189,600 Annual = $15, Monthly
Effective January 6, 2019
$192,300 Annual = $16, Monthly

6. Employee vs. Non-Employee Stipend Payments
2016 IRS Letter Ruling
Decision/Determination Matrix for Participant Support Participants and Consultant Payments
Link to College of Education guidance information can be found on GCA’s Main Webpage:

7. Employee vs. Non-Employee Stipend Payments
(Cont.)
Link on Website to the following Documents:
Participant Classification Workflow (Flowchart)
Employee vs. Contractor Classification Decision Matrix
For Employment based determinations:
Net Pay Estimates Chart (Proposal Preparation)
General Counsel Guidance on background checks
Grant Hire Communication Packets
Streamlined Grant Hire Applications

8. Sponsored Compensation Verification
July 1, 2018 – December 2018 period reports closed March 18, 2019 – 100% were approved.
Approved with Corrections need to be done by 6/30.
January 1 – June 30, 2019 period reports are scheduled to be released August 15, 2019.
Proactive processes:
A request from VPR to faculty to review their personnel on sponsored awards via FBIS was sent in April 2019.
Incorporating a review of Salaries paid over the HHS cap on HHS awards.

9. Cost Transfer Metrics FY18 vs FY19
Description
FY18
FY19 (as of 6/10/19)
Variance %
# of Requests
229
199
(30)
(13%)
$ Personnel
$1,256,705
$920,774
($335,931)
(27%)
$ Non-Personnel
$308,528
$281,758
($26,770)
(9%)
TOTAL
$1,565,233
$1,202,532
($362,701)
(23%)
# < 90 days
174
136
(38)
(22%)
# > 90 days 85
---

10. Cost Transfers FROM Fund 20 projects
Cost Transfer Policy Definitions:
Cost Transfer: An after-the fact reallocation of a cost (expenditure) from one project to another.
Timely Manner: Less than 90 days after the original posting date. For the purpose of this policy, the transfer is a correction to a sponsored project that was previously recorded elsewhere, i.e. any other project, regardless of the fund group, on Clemson University’s General Ledger.

11. Cost Transfers FROM Fund 20 projects (Cont.)
The Main Objective is to REDUCE RISK
A Reminder of Things Not to Do:
Use cost transfers as a means to manage grant expenses (ex. Temporarily “parking” expenses intended for another project and then moving them later to the appropriate project, etc)
Move expenses from a Fund 20 project to a non-sponsored fund to later move again to a Fund 20 project to avoid justification and additional scrutiny of charges on a project.

12. QUESTIONS