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The Office of Research Services The Office of Research Support Services 1 REVISED April, 2012 Post Award Primer and Terminology, Management and Reporting.

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Presentation on theme: "The Office of Research Services The Office of Research Support Services 1 REVISED April, 2012 Post Award Primer and Terminology, Management and Reporting."— Presentation transcript:

1 The Office of Research Services The Office of Research Support Services 1 REVISED April, 2012 Post Award Primer and Terminology, Management and Reporting Tools, Closeouts and Audits Sponsored Programs at Penn

2 The Office of Research Services The Office of Research Support Services 2 REVISED April, 2012 The FDP Federal Demonstration Partnership is a cooperative initiative among federal agencies and institutional recipients of federal funds. It was established to increase research productivity by streamlining the administrative process and minimizing the administrative burden on principal investigators while maintaining effective stewardship of federal funds. Penn is a participating institution Many of the recommendations of the FDP have been included in expanded authorities.

3 The Office of Research Services The Office of Research Support Services 3 REVISED April, 2012 Carryover Authority & SNAP Carryover Authority –Generally R’s, K’s and P01’s, but always check the Notice of Grant Award. SNAP Streamlined Non-competing Award Process –Generally R’s, K’s –A grant must have carryover authority if it is under SNAP

4 The Office of Research Services The Office of Research Support Services 4 REVISED April, 2012 Importance of Expanded Authorities/FDP Allows some administrative privileges authorized by A-110: Automatic carryover of unobligated balances across budget periods and competitive segments (except when noted in the Award) Up to one year no cost extension if requested 10 days prior to end of budget period (to complete project & not spend the $)

5 The Office of Research Services The Office of Research Support Services 5 REVISED April, 2012 Importance of Expanded Authorities/FDP Waive most cost related and administrative “prior approvals” except: –Change in scope or objective of the project –Change in key personnel –Requests for additional funding –Other exceptions as noted Allows for 90 day Pre-award startup costs

6 The Office of Research Services The Office of Research Support Services 6 REVISED April, 2012 Remember! At Penn, grants with automatic carryover retain same fund # for the entire segment. –An exception to this rule is subcontracts. All grants without automatic carryover receive a new fund # every new budget period. Understanding this most basic concept helps you understand when a fund # should expire, require a closeout, or when an advance account may be needed as the project continues. IT IS VITAL TO UNDERSTAND THIS!!!! IT IS VITAL TO UNDERSTAND THIS!!!!

7 The Office of Research Services The Office of Research Support Services 7 REVISED April, 2012 Basic Terms to Know Revenue Recognition PBIL and PBUD FSRD and FSRI Operating Budget Object Code 1220 Receivable Adjustment Period MTDC Encumbrance/Unliquid ated Obligation Unobligated Balance Letter of Credit

8 The Office of Research Services The Office of Research Support Services 8 REVISED April, 2012 Revenue Recognition Revenue Our entitlement to be reimbursed by the sponsor for the allowable expenditures of the grant An equal $ of Revenue is recognized for every $ of allowable expense in object code 4600 Grant Revenue Unallowable expenses and expenses above the award amount do not recognize revenue Revenue does not necessarily reflect the cash received from the sponsor WHAT’S WRONG WITH CHARGING AN INDIRECT COST DIRECTLY TO THE GRANT ?

9 The Office of Research Services The Office of Research Support Services 9 REVISED April, 2012 Other Potential Sources of Revenue on a Grant Fund University Funded Cost Sharing - Object Code 4822 TIF (Interest) Income - Object Code 4780 Program Income - Object Code 4620 In the end (at closeout and disablement of the fund), all sources of Revenue must equal Total Expense.

10 The Office of Research Services The Office of Research Support Services 10 REVISED April, 2012 Grant Receivables (Object Code 1220) As payments are received from the sponsor, the Receivable decreases (a credit) As Revenue is recognized (a credit), the Receivable increases (a debit) Positive Receivable: Expenditures > Cash Received Negative Receivable: Cash Received > Expenditures

11 The Office of Research Services The Office of Research Support Services 11 REVISED April, 2012 Grant Receivables (Object Code 1220) LOC Letter of Credit funds have a zero receivable. The actual receivable resides in a special holding fund for all funds under the specific LOC.

12 The Office of Research Services The Office of Research Support Services 12 REVISED April, 2012 Special Object Codes (entered by Research Services) PBIL - The Maximum Billable Award PBUD - Authorized Project Budget FSRD - The Total Direct Costs reported to the sponsor FSRI - The Total Indirect Costs reported to the sponsor

13 The Office of Research Services The Office of Research Support Services 13 REVISED April, 2012 More on PBIL PBIL Serves as the control and limits revenue recognition up to award amount Gets reduced to reported amount and guarantees that revenue recognition above reported amount does not occur Will always be rounded to nearest dollar. Cents will only show if there has been a carryover of funding from a previous fund (increase) or has been adjusted to the reported amount (decrease)

14 The Office of Research Services The Office of Research Support Services 14 REVISED April, 2012 More on PBUD PBUD Most often equal to PBIL except on advance accounts

15 The Office of Research Services The Office of Research Support Services 15 REVISED April, 2012 Operating Budget (Entered by Administrator)

16 The Office of Research Services The Office of Research Support Services 16 REVISED April, 2012 Unliquidated Obligations/ Unobligated Balance Unliquidated Obligations –Commitments of the budget period not yet paid –When reported funding gets reserved in the next budget period so they can be paid –Must liquidate within 90 days (A-110) –Can not be reported in the final period Unobligated Balance –unspent and uncommitted –may be able to carryover automatically or with approval

17 The Office of Research Services The Office of Research Support Services 17 REVISED April, 2012 Project Management and Reporting Tools Sponsored Programs at Penn

18 The Office of Research Services The Office of Research Support Services 18 REVISED April, 2012 Project Management Agenda Communication Establishing the Project Environment Managing Monthly Monitor Expenditures Cash Management

19 The Office of Research Services The Office of Research Support Services 19 REVISED April, 2012 Communication Report monthly to PI –Establish payroll distribution Establish level of effort anticipated for each individual on project – Be mindful of Salary cap limitations –Restrictions on spending Special Terms and Conditions within Award Notice –Monitor Subcontracts = Confirm amounts & work done Review each invoice (SPP #2131, #2135 Sub-recipient Monitoring policies)#2131#2135 Communicate regularly with ORS –Extensions / Continuations and other project changes –Financial reports, delinquent sponsor payment –Inform Sponsor via ORS of any Programmatic changes –Assesses allowability of costs

20 The Office of Research Services The Office of Research Support Services 20 REVISED April, 2012 Support the Project Work with PI on on-going basis Ensure that interim reports & proposals are submitted on time Disclose Inventions and Patents Prepare for Progress Reports and Non-Competing Continuations

21 The Office of Research Services The Office of Research Support Services 21 REVISED April, 2012 Establishing the Project Environment Payroll Set-up Identify who belongs on distribution Identify amount of funding and % effort Distribution Stop Date s/b set to the Account End Date Salary Encumbrances are calculated through the Current Budget End Date or Distribution Stop Date (whichever is earlier)

22 The Office of Research Services The Office of Research Support Services 22 REVISED April, 2012 Procurement Ben Buys Commodity Matrix –Methods of Purchasing –When should C-1, C-1A, C368, Purchase Order, or P-Card be used http://www.purchasing.upenn.edu/buyinfo/matrix.php Competitive Bids Required on aggregate purchases > $5,000 unless purchase is with a University Contract Supplier or with a supplier participating in the Penn Marketplace.

23 The Office of Research Services The Office of Research Support Services 23 REVISED April, 2012 Cost Share Types of Cost Share –Mandatory – costs required by terms of award that the University must contribute toward project in order for award to be made. –Voluntary Committed – costs associated with project (identified in proposal or budget justification) for which funding has not been requested from sponsor. –Voluntary Uncommitted – costs associated with project NOT identified within proposal or budget justification and NOT funded by sponsor. –In-Kind / Matching - Refers to funds being matched in some proportion with non-sponsored project funds, or that the grantee participate to some extent in the cost of the project. Matching requirements may be in the form of an actual cash expenditure of funds, or may be an “in-kind” match, which is the value of non-cash contributions to the project. Tracking Cost Share Commitments –Costs must be expended as proposed and recorded throughout life of project (separate fund ?) –Same allowability rules apply & same performance period as primary award

24 The Office of Research Services The Office of Research Support Services 24 REVISED April, 2012 Program Income Definition –Gross income earned that is directly generated by a sponsored activity or earned as a result of the sponsored activity Some examples: Income from fees or services performed from external entities or within University, Revenue from sale of tissue harvested from project. Methods of Program Income –Additive = income is added to sponsor commitment. –Deductive = income used to reduce sponsor commitment. –Matching = income used to finance portion of departmental commitment. Tracking Program Income –Program income rec’d from external entities must be deposited into o/c 4620 –Revenue earned by University dept for fees or selling goods or services to another Univ. dept is consider internal revenue and must be recorded using o/c 5500. –Program Income fund is to be set-up to account separately for the costs of collecting and spending the Program Income Awards in which Gross Program income may be off-set by the costs of collecting the income to enable reporting Net Program Income. ($5,000 threshold)

25 The Office of Research Services The Office of Research Support Services 25 REVISED April, 2012 Issues Surrounding Specific Expense Categories

26 The Office of Research Services The Office of Research Support Services 26 REVISED April, 2012 Equipment Definition – tangible, nonexpendable, personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit Must be necessary for project purposes –During the award period Is not reasonably available for use elsewhere in the University Award notice does not constrain equipment purchases Must obtain necessary bids, unless sole source justification Document whether Equipment is –Government owned –Government furnished Disposition after the project has ended –Know sponsor regulations

27 The Office of Research Services The Office of Research Support Services 27 REVISED April, 2012 Foreign Travel Foreign Travel must be included in proposal or otherwise be allowed by sponsor. Be sure to justify and document changes (approval, if applicable) if not in proposal –Department must maintain documentation in the file that supports the trip’s purpose Foreign air travel paid with federal funds must be on US-flag air carriers –Limited exceptions and they can be found out: www.access.gpo.gov/nara/cfr/cfr-retrieve.html#page1 www.access.gpo.gov/nara/cfr/cfr-retrieve.html#page1 Exceptions, which must be documented, generally include: –US-flag air carrier does not go to destination –Total trip time extended more than 24 hours –Lay-over extended more than 6 hours –Foreign carrier eliminates 2 or more changes

28 The Office of Research Services The Office of Research Support Services 28 REVISED April, 2012 Consultants Evaluate: Consultant, Employee or Subcontractor? –Use C-12 Independent Contractor Determination & Certification http://www.finance.upenn.edu/comptroller/tax/contractor_ certif.shtml Consulting agreement needs to be completed and forwarded to ORS for approval & signature Document role of consultant –Needs to be working towards goals of project to which he/she is charged Review sponsor guidelines for consultants –Ensure approvals are obtained, if applicable –Consultant rates may be limited for some sponsors

29 The Office of Research Services The Office of Research Support Services 29 REVISED April, 2012 Purchases PI approval process for purchases Assess allowability, allocability and reasonableness Verify budget and availability of funds Procure bids “Buy American” on federal awards when possible Don’t buy capital equipment at end of project

30 The Office of Research Services The Office of Research Support Services 30 REVISED April, 2012 Service Centers Definition: –A department or functional unit within a department, which performs specific service for a fee – Examples: Cell Sorting facilities, Resonance Imaging facilities, and Animal Care facilities ORS responsible for review & approval of rates –Services provided charged based actual use of services –Charges for services allocated monthly -Financial Policy #2115 University Service Centers Make sure Service Centers use correct fund account PI & BA should review Service Center charges regularly –The BA may not know what services were provided, or if the amount charged is appropriate

31 The Office of Research Services The Office of Research Support Services 31 REVISED April, 2012 Manage Monthly Plan expenditures in advance –This will make the project easier to manage throughout life of project Run and analyze appropriate reports –Financial Policy #1402.5 Monthly Closings/Reporting Send detailed reports to PI Remove unallowable and wayward charges Compare expenditures to projections Manage changes through full system –Changes in award value affect payroll –Changes in subcontracts or equipment affect F&A charges

32 The Office of Research Services The Office of Research Support Services 32 REVISED April, 2012 Manage Project Changes Proactively Use proposal as “home base” Anticipate necessary changes –Contact ORS for approval –Get sponsor approval through ORS –Change of scope or effort Plan ahead for extensions

33 The Office of Research Services The Office of Research Support Services 33 REVISED April, 2012 Monitor Expenditure Rates Sponsors question unusual expenditure rates Have we changed scope of work? Are we still breathing? Communicate with Sponsor (cc ORS)

34 The Office of Research Services The Office of Research Support Services 34 REVISED April, 2012 Cost Transfers The transfer of costs to sponsored projects where the costs initially had been incorrectly charged to another account. Any cost transfers that occur need to be properly justified and documented. University Financial Policy Number 2113 Cost Transfers and Payroll Reallocations states "Cost transfers must be prepared and submitted within 90 days from month end in which the transaction appears on the fund." Failure to adhere to this policy may result in the University disallowing the transfer which would result in a write-off to the administering department.Cost Transfers and Payroll Reallocations

35 The Office of Research Services The Office of Research Support Services 35 REVISED April, 2012 Cost Transfers Must be an allocable, allowable and justified charge to the particular award Department must maintain documented justification for transfer Must be made within time constraints

36 The Office of Research Services The Office of Research Support Services 36 REVISED April, 2012 New Cost Transfer J/E Categories On 7/1/2010, an additional BEN Financials Journal Entry Responsibility titles Journal Entry – G&C Costs Transfers was introduced to improve monitoring, tracking and compliance with the University’s cost transfer Financial Policy # 2113. –Initially added 15 G&C UN90 and 16 G&C OV90 On 10/4/2010, updates were made BEN Financials Journal Entry Responsibility to add 2 additional Categories. –17 UPHS Gds/Svs –18 UPHS Payroll

37 The Office of Research Services The Office of Research Support Services 37 REVISED April, 2012

38 The Office of Research Services The Office of Research Support Services 38 REVISED April, 2012 Cost Transfer Principles Cost transfers are for correcting legitimate ERRORS Cost transfers should NOT be used as a means of managing cash flow Project funds are NOT interchangeable –Integrity of each grant account must be maintained Allowability of costs must be maintained

39 The Office of Research Services The Office of Research Support Services 39 REVISED April, 2012 Cost Transfers Documentation –Supported by full explanation and justification, as well as a certification of the propriety of the transfer –Explanations such as “to correct error” or “to transfer to correct project” are not sufficient –Approval can be documented by PI signature Printed e-mail messages from PI

40 The Office of Research Services The Office of Research Support Services 40 REVISED April, 2012 Cost Transfer “Red Flags” Transfers made in excess of 90 days after the original charge Improper J/E Categories (15 G&C UN90, 16 G&C OV90) Transfers without a full explanation High volume of transfers Timing and “route” of transfers Late transfers to funds with unexpended funds Transfers from funds with overdrafts to other 5 fund(s) Transfers between funds with scientific overlap

41 The Office of Research Services The Office of Research Support Services 41 REVISED April, 2012 Advance Accounts for Continuation Awards Recommended for non-competing renewals requiring new fund #’s for each period –Department requesting the advance account bears the risk of having to fund any costs incurred if the funding never materializes –Med School sets up NIH advances for full budget period –All other Schools set up Advances for 3 month period

42 The Office of Research Services The Office of Research Support Services 42 REVISED April, 2012 Monitoring Accounts Receivable For Letter of Credit awards, check revenue & cash received. There should be no cash on hand. On Letter of Credit, confirm that PBIL is correct Contact ORS to address payment problems with sponsors –Departments should review AR and contact ORS regarding aged receivables of concern For awards on payment schedule, contact Bob Speakman For all other awards, contact Gokila Venkateswaran For Med School awards, ORSS representative is Danielle DiIanni

43 The Office of Research Services The Office of Research Support Services 43 REVISED April, 2012 Checks, Payments and Project Budget Increases Hand carry check to ORS immediately, with project identification –Do not deposit check Should AIS be increased because of check?

44 The Office of Research Services The Office of Research Support Services 44 REVISED April, 2012 Run and Review Reports BEN Reports –102.ORG – Summary CNAC-ORG-FUND level –115.ORG – Fund Summary –133.ORG – Due to Close –134.ORG – Summary of Final Expenditure Report Data Warehouse –Fund Summary –Org Summary –Corporate Documents Payroll Correct Errors

45 The Office of Research Services The Office of Research Support Services 45 REVISED April, 2012 Reporting Tools “There are so many reports I’m not sure where to look first.”

46 The Office of Research Services The Office of Research Support Services 46 REVISED April, 2012 GRAM / BEN Reports Reports used primarily by Principal Investigators Reports represent a Current Budget Period perspective Not easy to determine PJTD Numbers or amount to close out at (other than Budget Available) Critical for Operating Budget to be posted to the Budget Period Start GRAM – The online PI view

47 The Office of Research Services The Office of Research Support Services 47 REVISED April, 2012 Actual Spent represents Current Budget Period Only Further Detail can be clicked on, but none is available for Prior Budget Periods

48 The Office of Research Services The Office of Research Support Services 48 REVISED April, 2012 Management of All Grants in ORG BUSINESS OBJECTS ORG Summary by Fund, PI, Acct End, receivables, overdrafts, funds freezing, late/due FSR’s, Analysis of expired funds, Illegal object code charges, possible F&A direct charged to Fed grants, payroll compared to budget. Grantmonitor PBIL/PBUD/Budget, NCC Due, Awards Due, Revenue Check, Overdrafts (active and expired), Federal Cash, CT Cash, Residual Balances, Receivables Subbudgets our charges to others Otherorgschgs ORG Wayward Summary.rep ORGpersonnel. all current distributions of home dept org Award Analysis- Award Date PT-Requests (all proposals submitted for any time period) JE inquiry (by batch between dates) FY Grant ORG Expense Analysis Effort Report – Home Dept ORG Object code by fund – posted org Object code by fund – detail AIS (full search) Protocols – Org/ Protocols – PI BEN FINANCIALS 132.ORG List of Terminated G&C Funds 133.ORG List of G&C Funds Due to Close 138.ORG Frozen Fund List 201.SCH PJTD Rev/Exp for G&C/URF 202.SCH YTD Rev/Exp Totals for Funds 211.SCH PJTD Rev/Exp Outline for G&C/URF 212.SCH YTD Rev/Exp Outline for G&C/URF 301.BUD Budgetable Amount - Grants/Contracts 306.BUD Negative BBA ORG/FUND/CREF PJTD

49 The Office of Research Services The Office of Research Support Services 49 REVISED April, 2012 Fund Level Management BUSINESS OBJECTS fundsummary fundsummary with BRIM fundsummary (w date range) summary by ORG/CNAC SNAP/NCC estimated unobligated balance Fund Detail monthly matrix all expense monthly matrix personnel paid FUNDpersonnel – all current distributions on fund Effort Report – Fund GRANT REPORTS (-Resp Org, -PI, -CREF, -PI Awarded) PI friendly & monthly payroll and expense detail BEN FINANCIALS 102.ORG Summary G&C by CNAC/ORG/FUND 103.ORG Summary G&C by CNAC/ORG/FUND/CREF 115.ORG Grant Fund Summary Report 130.ORG PI Report by CNAC/ORG/FUND 134.ORG Summary of Final Expenditure Report (available for grants in adjustment period) 137.ORG Grant/Contract Budget Period Summary

50 The Office of Research Services The Office of Research Support Services 50 REVISED April, 2012 Expense Detail BUSINESS OBJECTS Fund Detail. Payroll by Obj, by Person,Exp Detail by Object, Org, Acct Period, P.O./User Fund Detail – PI monthly matrix of personnel paid on PI grants Payroll.(any fund any period of time) variations include: All grants of PI All grants of Resp Org Personnel.(any person, any period) Personnel-one (any person’s current distrib) Detail. variations include: All grants of PI All grants of Resp ORG subcontracts object special budget operating budget cash deposits Encumbrances(Fund) ORG Wayward Detail BEN FINANCIALS 150.ORG Detail by CNAC/ORG/FUND 151.ORG Detail by CNAC/ORG/FUND/CREF 152.ORG Detail by CNAC/ORG/CREF 153.ORG Detail by CNAC/ORG/FUND/PROG 155.ORG Detail Extract 156.ORG Detail by CNAC/ORG/FUND/PROG/CREF 160.ORG Account Analysis with payables detail 163.ORG Open Encumbrances Report 301.BUD Budgetable Amount - Grants/Contracts 304.BUD Negative BBA ORG/FUND YTD 305.BUD Negative BBA ORG/FUND/CREF YTD 306.BUD Negative BBA ORG/FUND/CREF PJTD 315.BUD Posted Budget Journal with Exceptions 507.GA Posted Journal Activity Report 508.GA Unposted Journal Activity Report 510.GA Detail Transaction by OBJECT by ORG

51 The Office of Research Services The Office of Research Support Services 51 REVISED April, 2012 Your assignment Full documentation of the Business Objects Queries is available at: http://www.upenn.edu/computing/da/dw/financial_queries.html Select “Grants Management” While we will discuss and give samples of some of the more popular reports today, it is essential that you GO BACK TO YOUR OFFICE AND PLAY WITH THE REPORTS!!! Decide what tools/reports work best for you and your investigators.

52 The Office of Research Services The Office of Research Support Services 52 REVISED April, 2012 Award Analysis – Award Date

53 The Office of Research Services The Office of Research Support Services 53 REVISED April, 2012 FY Grant ORG Expense Analysis

54 The Office of Research Services The Office of Research Support Services 54 REVISED April, 2012 ORG Summary

55 The Office of Research Services The Office of Research Support Services 55 REVISED April, 2012 ORG Summary - Analysis of Expired Funds Why isn’t my fund disabled?

56 The Office of Research Services The Office of Research Support Services 56 REVISED April, 2012 ORG Summary – possible F&A

57 The Office of Research Services The Office of Research Support Services 57 REVISED April, 2012 Grant Reports PI Summary Tab

58 The Office of Research Services The Office of Research Support Services 58 REVISED April, 2012 Grant Reports PI Detail Tab

59 The Office of Research Services The Office of Research Support Services 59 REVISED April, 2012 Grant Reports Payroll Encumbrances Tab

60 The Office of Research Services The Office of Research Support Services 60 REVISED April, 2012 Grant Reports – PI Taken from the “PI Matrix –all” Tab

61 The Office of Research Services The Office of Research Support Services 61 REVISED April, 2012 Grant Reports – PI.rep Taken from the “Personnel Matrix” Tab. Note: this covers one period only. Fund Detail –PI.rep could do this for a range of dates

62 The Office of Research Services The Office of Research Support Services 62 REVISED April, 2012

63 The Office of Research Services The Office of Research Support Services 63 REVISED April, 2012 fundsummary – Award History tab

64 The Office of Research Services The Office of Research Support Services 64 REVISED April, 2012 fundsummary - SNAP/NCC Estimated Unobligated Balance Make sure the formula toolbar is checked under View Toolbar.

65 The Office of Research Services The Office of Research Support Services 65 REVISED April, 2012 fundsummary.rep – Cref Matrix

66 The Office of Research Services The Office of Research Support Services 66 REVISED April, 2012 Fund Detail.rep This is the “Acct Per. Summary Tab”. There is also a Pay Summary Tab as well as numerous tabs to sort payroll information and expense detail information. Variations of this include: Fund Detail-PI.rep and Fund Detail - cref detail.rep, and fundsummary (w date range)

67 The Office of Research Services The Office of Research Support Services 67 REVISED April, 2012 GrantMonitor This tab of the GrantMonitor can help identify NIH noncompeting Progress Reports that might be due. There are also separate tabs which can identify when Subcontracts Progress Reports are due and also T32’s based on which Institute the award is with.

68 The Office of Research Services The Office of Research Support Services 68 REVISED April, 2012 JE Inquiry (by batch between dates) Note the 3 tabs which are specifically designed for grant entries done by Res Svcs (8760) or the Comptroller’s Office (8720)

69 The Office of Research Services The Office of Research Support Services 69 REVISED April, 2012 AIS (full search) Ability to search on multiple criteria

70 The Office of Research Services The Office of Research Support Services 70 REVISED April, 2012 AIS (full search) The “New AIS Summary” Tab can give a summary of AIS’s issued in the last 35 days

71 The Office of Research Services The Office of Research Support Services 71 REVISED April, 2012 AIS (full search).rep

72 The Office of Research Services The Office of Research Support Services 72 REVISED April, 2012 Effort Report – Fund.rep

73 The Office of Research Services The Office of Research Support Services 73 REVISED April, 2012 Effort Report – Fund.rep

74 The Office of Research Services The Office of Research Support Services 74 REVISED April, 2012 Protocols – Org.rep This tab gives a summary of protocols by fund #. There are also separate tabs for Human Protocols by PI, Animal Protocols by PI, Protocols by #, and Expired Protocols.

75 The Office of Research Services The Office of Research Support Services 75 REVISED April, 2012 Identifying Waywards – 115.ORG The 115 shows a possible wayward charge from ORG 4227 Cardiology. To obtain the detail of the charge a 15X.ORG report can be run entering the ORG making the charge in the Accounting Period the charge was made.

76 The Office of Research Services The Office of Research Support Services 76 REVISED April, 2012 Otherorgschgs.rep & Waywards.rep

77 The Office of Research Services The Office of Research Support Services 77 REVISED April, 2012 In Summary Award must be reviewed on a regular basis Communication is vital to the proper administration of the award When you are not sure, investigate and ask If an award is properly managed, the closeout process is very simple

78 The Office of Research Services The Office of Research Support Services 78 REVISED April, 2012 Closeouts and Audits of Sponsored Project Funds Sponsored Programs at Penn

79 The Office of Research Services The Office of Research Support Services 79 REVISED April, 2012 Closeout of Sponsored Project Funds Agenda PI & Department responsibilities –Communication –Pre-closeout review –Adjustment period –Freeze/unfreeze grants –Technical & invention reports ORS responsibilities –Unfreeze requests –Financial & non-financial reports –Disabling accounts SPP # 2126 Interim & Final Financial Reports SPP # 2128 Account Close-out

80 The Office of Research Services The Office of Research Support Services 80 REVISED April, 2012 What is the Adjustment Period? Period of up to 60 days after Account end date –Allows for final review of project activity so adjustments can be made prior to final reporting 30/31 days: Account End Date + 15 days 45 days: Account End + 30 days 60/61 days: Account End + 30 days 90/91 days: Account End Date + 60 days

81 The Office of Research Services The Office of Research Support Services 81 REVISED April, 2012 Adjustment Period (cont.) Run 134.ORG Report in BEN Financials or Fund Summary in Business Objects –Review the following areas PBUD/PBIL should be equal Revenue vs. Expense –Should be equal –If not, requires further review –F&A and Employee Benefits (EB) – Were the correct rates appropriately applied?

82 The Office of Research Services The Office of Research Support Services 82 REVISED April, 2012 Adjustment Period (cont.) –Review the following areas (cont.) Payroll – Any adjustments that may be needed must be made by the end of the adjustment period Service Centers – Were these handled appropriately Cost transfers over 90 days that were done without prior approval Other direct costs for allowability

83 The Office of Research Services The Office of Research Support Services 83 REVISED April, 2012 Final Review Prior to End of Adjustment Period Review PBIL/PBUD, NOGA and approved carryforward, if applicable Review subcontracts and respective closeouts Communicate with ORS Accountant –Outstanding reporting/receivable issues Determine and address –Unliquidated and unobligated carryovers All adjustments must be processed by end of the fund adjustment period –Complete all approved, allowable, allocable and appropriate adjustments identified during pre- closeout review

84 The Office of Research Services The Office of Research Support Services 84 REVISED April, 2012 Best Practices for Communications Emails - the subject line of your email should be informative –“Action Fund#, P.I., Description –Examples: “Closeout 538500, Mendel, 5K23MH024680-03” “Unfreeze 538000, Frankenstein, 5R01HG012345-05 One email per fund action Email ORS Accountant and notify them of the Direct, Indirect, and Total Expenses to report hopefully by the end of the adjustment period but no later than 1 week before report due date.

85 The Office of Research Services The Office of Research Support Services 85 REVISED April, 2012 Freeze/Unfreeze Grant Functionality

86 The Office of Research Services The Office of Research Support Services 86 REVISED April, 2012 Freeze Grants Functionality Tool that allows authorized research administrators and ORS to limit activity against an award –Can be used during life of project and during the adjustment period –Can reduce cost transfers and overruns after the end of the fund project period –Improve timeliness and accuracy of final financial reports

87 The Office of Research Services The Office of Research Support Services 87 REVISED April, 2012 Freeze Grants Features Awards are frozen/unfrozen at fund level –Payroll can be frozen manually prior to the Account End Date –Functionality frozen automatically after Account End Date New Purchase Orders/Requisitions –Functionalities frozen automatically after Adjustment Period End Date (APED) Manual Journal Entries C-forms Feeder Journal Entries Payroll

88 The Office of Research Services The Office of Research Support Services 88 REVISED April, 2012 Unfreeze Request (cont.) Are not necessary to: –Prepare budget journals –Pay already encumbered amounts on an existing P.O. –Unfreeze advance accounts (request an extension of advance account)

89 The Office of Research Services The Office of Research Support Services 89 REVISED April, 2012 Unfreeze Grants (cont.) Submit your request to: –School of Medicine departments Send worksheet and details (including documentation) to Office of Research Services Support (ORSS) Grant Manager with a cc to ORS Accountant ORSS will review and, if approved, will forward to Research Services Accountant and cc Assistant Director –All other Schools Send worksheet and details to ORS Accountant and cc Assistant Director –Unfreeze requests are normally addressed within two business days

90 The Office of Research Services The Office of Research Support Services 90 REVISED April, 2012 ORS Responsibilities

91 The Office of Research Services The Office of Research Support Services 91 REVISED April, 2012 ORS Reporting Period Tasks Reviews Due Reports to determine report due date Email will be sent requesting closeout information ORS Accountant reviews the following; -Terms and conditions of award and sponsor reporting requirements –Review the 734 report in Business Objects (similar to 134.ORG report in Ben Financials) –Check PBUD/PBIL for accuracy –Reconcile EB’s, F&A and Cash –Review 252 report for stale dated checks

92 The Office of Research Services The Office of Research Support Services 92 REVISED April, 2012 ORS Reporting Period Tasks (cont.) Review expenses posted to the fund for allowability –Revenue 4600, 4620, 4630, 478X, 4822, TIF, Program Income & Other Revenue Review remaining balances or deficits ORS will communicate any issues identified and request a response from the BA If the ORS Accountant does not receive a response regarding closeout the report will be issued and an email will be sent stating what was reported to the sponsor.

93 The Office of Research Services The Office of Research Support Services 93 REVISED April, 2012 ORS Reporting Period Tasks (cont.) Overdrafts –ORS will contact department regarding resolution –If no response is received by report due date, fund will be reported up to award amount and ORS will process journal to transfer resources from departmental fund to grant fund to offset overdraft via object code 4822 SPP # 2129 Chargeback of Overdrafts and Disallowances

94 The Office of Research Services The Office of Research Support Services 94 REVISED April, 2012 ORS Reporting Period Tasks (cont.) Unexpended Balance –Will be reported to sponsor –Carryover will be processed and/or requested as appropriate –Residual cash will be remitted to sponsor according to agreement –Carryovers and/or unliquidated obligations will be determined and handled as appropriate

95 The Office of Research Services The Office of Research Support Services 95 REVISED April, 2012 ORS Reporting Period Tasks (cont.) Final Financial Status Report (FSR)/(FFR) Submission –Financial report will be issued by ORS no later than due date –A copy will be sent to department and a copy will be scanned into our imaging system (Acorde) –ORS will process any closing entries based upon final reports

96 The Office of Research Services The Office of Research Support Services 96 REVISED April, 2012 Revised FSR/FFR’s O nly done in rare circumstances When revising to increase total expenses, most sponsors will only accept revised reports for limited period of time following the end of the award. Some agencies will not accept upward revised FSRs. When revising to decrease total expenses, there is no time limit. These should be completed immediately upon identification of the need for a revised FSR. SPP # 2137 Revised Final Financial Reports

97 The Office of Research Services The Office of Research Support Services 97 REVISED April, 2012 Disabling Funds How does a fund get Disabled? –ORS runs 717.RA report in BEN Financial weekly To identify funds that meet disable requirements –If the fund is eligible for disabling ORS checks “Enable” flag Enters date in BEN Financials

98 The Office of Research Services The Office of Research Support Services 98 REVISED April, 2012 Requirements to Disable Funds 1.Financial Report must be submitted if required- Last FIN Report Filed=Next FIN Report Due 2.FSRD and FSRI s/b posted reflecting Direct and Indirect Costs reported 3.PBIL=PBUD=FSRD+FSRI=Total Expenses reported and on the G/L 4.No Encumbrances can remain 5.Object Code 1220 Receivable must =0 6.Equipment in Object Code 183X/187X must be transferred to School Surrogate Accounts via an Object Code 4826 Equipment Transfer 7.BRIM (ORS billing system) is reconciled (requires ORS action) 8.All stale dated checks have been satisfactorily addressed

99 The Office of Research Services The Office of Research Support Services 99 REVISED April, 2012 Miscellaneous - Cost Sharing (con’t.) Cost Sharing –How is it recorded in our system? Must be separately accounted - a 5 fund must be established if Cost Share > $10K –What needs to be done at closeout? Mandated cost sharing must be reported to the sponsor How is it managed? Expenses should be recorded and monitored on a timely basis Revenue entries must be routinely performed SPP #2119 Cost Sharing/Matching Requirements

100 The Office of Research Services The Office of Research Support Services 100 REVISED April, 2012 Miscellaneous – Interest Bearing Funds Interest Bearing Funds –When does an award fund receive interest? Monthly basis –How do I know if my fund is interest bearing? T&C of award determine –Can I spend these funds? T&C of award determine –At Closeout, what happens to these funds? T&C of award determine

101 The Office of Research Services The Office of Research Support Services 101 REVISED April, 2012 Miscellaneous – Program Income Program Income –What is Program Income? Gross income earned & directly attributable to the sponsored activity –How is Program Income handled? Additive vs. Deductive –How is Program Income handled at closeout? SPP #2121 Accounting for Program Income

102 The Office of Research Services The Office of Research Support Services 102 REVISED April, 2012 Miscellaneous – Record Retention What do I need to retain? How long do I need to keep it? SPP #2132 Record RetentionSPP #2132 Record Retention

103 The Office of Research Services The Office of Research Support Services 103 REVISED April, 2012 Miscellaneous – Award Transfers If a PI is planning to leave the University, ORS staff should be contacted as soon as possible to expedite the process “Statement of Relinquishment” or similar document –Required information must be verified –ORS signature must be obtained –Estimated unobligated balance-funds awarded on NOGA for current year only exclusive of any amounts carried over –Not finalizing costs may delay transfer of funds to the next University –Any property being transferred must be addressed

104 The Office of Research Services The Office of Research Support Services 104 REVISED April, 2012 Non-Financial Close Out Issues Final technical and/or progress report Final invention statement Final property report

105 The Office of Research Services The Office of Research Support Services 105 REVISED April, 2012 Getting Assistance on Closeouts For financial matters: –Contact ORS accountant or Post- Award Assistant Director Regarding extensions, requests for budget or other modifications to agreement, or non-financial matters: –Contact your Contract Administrator

106 The Office of Research Services The Office of Research Support Services 106 REVISED April, 2012 Questions???

107 The Office of Research Services The Office of Research Support Services 107 REVISED April, 2012 Audits Sponsored Programs at Penn

108 The Office of Research Services The Office of Research Support Services 108 REVISED April, 2012 Pre-Award Audits Performed by agency to verify –Accuracy of costs on application –Adequacy of University systems and controls Usually performed by or at the request of the sponsor Federal Awards –DHHS is Cognizant Agency –Sponsoring Agency

109 The Office of Research Services The Office of Research Support Services 109 REVISED April, 2012 Agency or Programmatic Audits Performed on Active or Terminated awards Federal Awards normally a result of a request by the Sponsor –Review by Dept of Health & Human Services (DHHS) –Foundations and Associations –Other

110 The Office of Research Services The Office of Research Support Services 110 REVISED April, 2012 Investigative/Criminal Audits Usually based on allegations of fraud –Misuse of funds on awards including: Purchasing Card charges Petty Cash abuses –Audit of how we comply with regulations –If Federal OIG audit Subpoena powers

111 The Office of Research Services The Office of Research Support Services 111 REVISED April, 2012 Internal Audits University audits projects to –Evaluate system controls –Assess compliance with University and sponsor policies and applicable OMB circulars –Investigate reports of fraud

112 The Office of Research Services The Office of Research Support Services 112 REVISED April, 2012 Compliance Audits Assess compliance with –Sponsor regulations –University policies Human Subject/Animal issues

113 The Office of Research Services The Office of Research Support Services 113 REVISED April, 2012 F&A Cost Proposal Audits Audit occurs cyclically –During the F&A negotiation process F&A recovery rates are affected by expenditures Interviews of PI and BA to determine basis for assigning space to research –Space drives the rate –32.5 points of 57% rate

114 The Office of Research Services The Office of Research Support Services 114 REVISED April, 2012 OMB Circular A-133 Audit Required annual audit of federal grants & contracts Performed by independent auditors –Penn: PricewaterhouseCoopers (PwC) Audit of systems and transactions Cost Transfers, Effort Reports, Subcontracts, Service Centers, Technical & Financial Reports

115 The Office of Research Services The Office of Research Support Services 115 REVISED April, 2012 General Principles for Audits Good award management is the key to good (uneventful) audits Good documentation is essential in –Department and ORS Audits are everyone’s responsibility –PI, BA, School, Pre and Post-award in ORS –Don’t go in alone

116 The Office of Research Services The Office of Research Support Services 116 REVISED April, 2012 Audited on compliance with all applicable regulations & policies –Federal –State –Sponsor –Specific award terms –University General Principles for Audits (cont.)

117 The Office of Research Services The Office of Research Support Services 117 REVISED April, 2012 General Principles for Audits (cont.) Audited on consistency of policy application Audits may provide feedback for process improvement Audit results can be expensive ORS & PI have a responsibility to educate the auditor about the purposes of the project

118 The Office of Research Services The Office of Research Support Services 118 REVISED April, 2012 Preparing for Audits Notify ORS as soon as you learn of audit –SPP #2130 External AuditsSPP #2130 External Audits ORS & PI/BA meet to prepare for audit –Anticipate questions –Develop procedures for working with auditors File management Prepare and support the PI –Work to prevent adversarial relationship Don’t panic

119 The Office of Research Services The Office of Research Support Services 119 REVISED April, 2012 Audit Lessons Learned

120 The Office of Research Services The Office of Research Support Services 120 REVISED April, 2012 Critical Audit Concerns Salary Charges on Awards –Effort on award must equal or exceed salary charged –Effort must be documented in Personnel Activity Report form –Payroll Reallocations Same as Cost Transfers –Communicate with PI

121 The Office of Research Services The Office of Research Support Services 121 REVISED April, 2012 Critical Audit Concerns (cont.) Cost Transfers –Auditors view them as corrections of errors –Explain why the error occurred –Establish correlation of charge to next grant –Provide documentation –Maintain documentation in file –Cost Transfers must be prompt and justified –“Parking” a charge is illegal

122 The Office of Research Services The Office of Research Support Services 122 REVISED April, 2012 Critical Audit Concerns (cont.) Documentation –Costs that deviate from the proposal must be justified in terms of the project –Maintain all approvals from sponsor –Explain why decisions were made –PI must approve costs incurred on award

123 The Office of Research Services The Office of Research Support Services 123 REVISED April, 2012 Critical Audit Concerns (cont.) Consultants –Document relationship with consultants Do not circumvent IRS employee regulations Do not engage an employee of sponsor or Penn employee as a consultant –Consulting agreement (work for hire) must document scope of work, rate and payment terms Proper inventory of equipment –Tag & document transfer, move or disposal

124 The Office of Research Services The Office of Research Support Services 124 REVISED April, 2012 Critical Audit Concerns (cont.) Service Centers are reviewed (A-133 & F&A proposal) –Surpluses are problematic Are federal awards being overcharged? –Rates must be adjusted to off-set the surplus –At least annually adjust to compensate for surplus or deficit –Maintain documentation of charges –Maintain records of rate determination SPP #2115 University Service Centers

125 The Office of Research Services The Office of Research Support Services 125 REVISED April, 2012 Critical Audit Concerns (cont.) Subcontracts –PI must monitor subrecipient performance and expenses –Subrecipient must verify that it is not debarred or suspended –ORS monitors subrecipient audit reports If findings result from expenditures of subcontract, Penn department is responsible for the cost of findings.

126 The Office of Research Services The Office of Research Support Services 126 REVISED April, 2012 Critical Audit Concerns (cont.) Close-Out –Penn must submit all required reports Programmatic, Financial, Patent, Property –Timeliness of reports

127 The Office of Research Services The Office of Research Support Services 127 REVISED April, 2012 If you are contacted by a sponsor regarding an audit… …Contact ORS Executive Director

128 The Office of Research Services The Office of Research Support Services 128 REVISED April, 2012 Questions???

129 The Office of Research Services The Office of Research Support Services 129 REVISED April, 2012 Resources Sponsored Programs at Penn

130 The Office of Research Services The Office of Research Support Services 130 REVISED April, 2012 ORS Website and Resource Tour http://www.upenn.edu/researchservices/ –Homepage –Left Quick Links –Sponsored Projects Manual –Sponsor Links –Spotlights –ORS Newsletters and listserv –Brown Bags and other Training Opportunities


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