1. Office of Research Administration Faculty Forum September 26, 2007

2. Vision To serve the campus community in its research initiatives in order to provide operational effectiveness of the research enterprise while maintaining regulatory compliance.

3. Office of Research Administration Recent changes in the Office of Research Administration were made to: Enhance Customer Service to the research community Change the “service culture” Reorganized staff to focus service for departments Reorganized staff to consolidate financial management under ORA Ensure research compliance Policies Procedures Training Other

4. Results Communication to research community  E-mail updates  Response time to inquiries  Training and education to research community  Monthly research reports to DHHD’s  One stop shopping Streamline signature process for proposals and awards

5. Results Productivity metrics for establishment of a fund. Prior to Feb 07:  48% set up within 30 days of start date  34% set up within 14 days of start date  36% set up after 60 days of start date After Feb 07:  69% set up within 30 days of start date  54% set up within 14 days of start date  12% set up after 60 days of start date

6. Research Compliance Currently in an environment of greater scrutiny by the federal government on the compliance of the use of federal dollars Areas of Compliance : Security and Biosafety Select Agents Export Controls Foreign Nationals Publication restrictions Sensitive and Classified data Technology Transfer Bayh-Dole Act Human Subjects HIPAA

7. Research Compliance Areas of Compliance: Financial Office of Management and Budget (OMB) Circulars: A-21 A-110 A-133 Conflict of Interest Scientific Misconduct Animal Welfare State of Colorado Contracts Fiscal Non-compete

8. Research Compliance Recent Federal government focus in the financial compliance arena specific to the compliance of the OMB A-21 circular: Cost Sharing Effort Reporting Cost Transfers Administrative and Clerical Salaries Monitoring of Sub-recipients (OMB A-133 compliance supplement)

9. Research Compliance Inspector Generals (NIH, NSF, others) performing subject target audits: NSF OIG found U of Hawaii cost sharing certifications not supported NMHU cost sharing tracking system inadequate UPENN non compliant with effort reporting processes: timeliness, and documented verification Georgia State University - $400,000 unallowed for deficient sub recipient monitoring NIH OIG found: Yale non compliant with cost transfers, effort reporting and cost allocations – resulted in disallowed funds

10. Research Compliance DOJ found UConn non compliant with many research administration practices characterized as “sloppy recordkeeping and poor management of grants” – resulted in $2.5 million disallowed. UConn instituted mandatory training program for all faculty and staff associated with research ED disallowed $500,000 of funding to the Colorado Community College system due to deficiencies in effort reporting HHS OIG inquiry to CSM on it’s findings indicated in the June 30, 2005 audit EPA audit on CSM in FY2006. Disallowed expenses and found deficiencies in effort reporting DOE inquiry to CSM about FY06 audit findings prior to award of grants

11. Research Compliance CSM Plan Education and training for faculty and staff Guidance for the research community Policy review and development: Sub Recipient Monitoring procedures (done 6/06) Cost Transfers (done 7/1/07) Tuition remission (done 9/1/07) Recharge Center rates (drafted) Effort Reporting Cost Sharing Direct vs. Indirect charges Allowable vs. Non-Allowable charges Export Controls Others Working with the State on removing certain State requirements Immediate changes for known non-compliant matters

12. Audit Industry Focus CSM is subject to various audits: Required annual audits Financial – All activity Compliance (OMB A-133) – Sponsored activity Defense Contract Auditing Agency (DCAA) – F&A and Fringe rates Others OIGs Sponsors Internal State

13. Audit Industry Focus Potential ramifications of having deficient audits: Risk of loss of sponsor funding Risk of loss of state funding Increased audit scrutiny Increased state oversight

14. INTRODUCTION TO OMB CIRCULAR A-21 DEFINES AN "ALLOWABLE COST". Available at http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html INSTRUCTIONS FOR THE UNIVERSITY TO ALLOCATE INDIRECT COSTS PROPERLY AND TO CALCULATE THE INDIRECT COST RATE APPLIES TO PROJECT(Direct) COSTS REIMBURSED BY THE GOVERNMENT AND TO COST SHARING OR MATCHING FUNDS GENERAL REQUIREMENTS: REASONABLE ALLOCABLE TO (BENEFITS) THE PROJECT SUPPORTED BY THE GRANT OR CONTRACT TREATED CONSISTENTLY (INCLUDING CONSISTENT TREATMENT AS EITHER A DIRECT OR INDIRECT COST

15. UNALLOWABLE COSTS Advertising and public relations costs (with specific exceptions) Alcoholic beverages Alumni activities Bad debts Institution-furnished automobiles Commencement costs Donations or contributions Entertainment Lobbying Fines and penalties Goods and services for personal use

16. UNALLOWABLE COSTS (cont’d) Housing and personal living expenses Interest, fund raising and investment management costs Membership in social, dining, country clubs, or civic organizations Selling and marketing Student activities Airfare costs in excess of the lowest available commercial discount airfare (with specific exceptions) Awards, prizes, trophies Flowers, gifts Parking tickets

17. DIRECT vs INDIRECT COSTS What are direct costs? Identified specifically with a particular sponsored agreement and incurred to advance the work under that agreement Assigned to a sponsored agreement relatively easily and with a high degree of accuracy

18. DIRECT vs INDIRECT COSTS What are F&A costs (Indirect costs)? Benefit common or joint activities Benefit numerous projects Cannot readily be identified with a particular sponsored project Cannot be proportioned to benefit a group of sponsored projects with relative ease or with a high degree of accuracy

19. NORMALLY Indirect costs Administrative and Clerical Salaries Office supplies, postage, dues and memberships, local telephones(telephone equipment) Computers – can be either an indirect cost or a direct cost depending on the scope of work of the project (Justification form) A-21 Exhibit C provides for exceptions for charging normally indirect costs if the project is a major project

20. ORA ORA is focused on serving the campus community in its research initiatives in order to provide operational effectiveness of the research enterprise while maintaining compliance.

21. Information available ORA web site: http://www.is.mines.edu/ors/ Contact ORA staff

22. Questions

23. Thank you!