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The Office of Research Services The Office of Research Support Services 1 Revised October 8, 2008 Module 1 Introduction to Sponsored Projects Administration.

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Presentation on theme: "The Office of Research Services The Office of Research Support Services 1 Revised October 8, 2008 Module 1 Introduction to Sponsored Projects Administration."— Presentation transcript:

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2 The Office of Research Services The Office of Research Support Services 1 Revised October 8, 2008 Module 1 Introduction to Sponsored Projects Administration Sponsored Programs at Penn

3 The Office of Research Services The Office of Research Support Services 2 Revised October 8, 2008 Welcome to Sponsored Programs at Penn Modules –Module 1 – Introduction to Sponsored Projects Administration at Penn –Module 2 – Proposal Preparation and Submission & Budgeting –Module 3 – Award Setup and AIS Information –Module 4 – Project Management and Reporting Tools –Module 5 – Closeouts and Audits

4 The Office of Research Services The Office of Research Support Services 3 Revised October 8, 2008 Handouts Sponsored Projects Manual and Policies Module Handouts and Reference Materials Penn Research Admin. File (to be completed during SPP)

5 The Office of Research Services The Office of Research Support Services 4 Revised October 8, 2008 Anticipated Benefits of Program Introduction of resources and tools available to Research Administrators at Penn Overview of general terms Overview of federal and sponsor rules and regulations related to sponsored projects Clarification of responsibilities Building strong, informed Penn Research Administrators

6 The Office of Research Services The Office of Research Support Services 5 Revised October 8, 2008 What is a Sponsored Project? Any project, which meets any of the following criteria, is considered to be a "sponsored project" and will be administered accordingly: –The project commits the University to a specific line of scholarly or scientific inquiry, typically documented by a statement of work; –A specific commitment is made regarding the level of personnel effort, deliverables, or milestones; –Project activities are budgeted, and the award includes conditions for specific formal fiscal reports, and/or invoicing; –The project requires that unexpended funds be returned to the sponsor at the end of the project period; –The agreement provides for the disposition of either tangible property (e.g., equipment, records, technical reports, theses or dissertations) or intangible property (e.g., inventions, copyrights or rights in data) which may result from the project; –The sponsor identifies a period of performance as a term and condition Administration of Sponsored Projects

7 The Office of Research Services The Office of Research Support Services 6 Revised October 8, 2008 Grant Purpose: –To transfer … Money Property Services Or anything of value … to recipient in order to accomplish a public purpose. Involvement: –No substantial involvement is anticipated between government and recipient during the performance of activity.

8 The Office of Research Services The Office of Research Support Services 7 Revised October 8, 2008 Contract Purpose: To acquire property or services for direct benefit or use of the federal government. Involvement: Varying amounts anticipated between government and recipient during performance of activity.

9 The Office of Research Services The Office of Research Support Services 8 Revised October 8, 2008 Cooperative Agreement Purpose: To transfer funds to recipient to accomplish a public purpose. Involvement: Substantial amounts anticipated between government and recipient during performance of activity.

10 The Office of Research Services The Office of Research Support Services 9 Revised October 8, 2008 RFProposal Government generates scope of work via Notices/Program Announcements. You respond with how you will accomplish, budget and time frame. Contract is usual award document for RFP/RFQ while a grant/cooperative agreement is usual award document for RFA. RFQuotation RFApplication

11 The Office of Research Services The Office of Research Support Services 10 Revised October 8, 2008 Grant vs. Contract GrantContract Project conceived by: InvestigatorAgency Agency function: Supports or assists Procures service Control:Performer defines details and retains scientific freedom Agency exercises direction or control Agency oversight: Maintains cognizance Closely monitors

12 The Office of Research Services The Office of Research Support Services 11 Revised October 8, 2008 Cooperative Agreement Grant Contract In Between

13 The Office of Research Services The Office of Research Support Services 12 Revised October 8, 2008 GRANTCOOPERATIVE AGREEMENT CONTRACT Basic Purpose Provides assistance with few restrictions Provides assistance with subsantial involvement between parties Procure Tangible goods and services Solicitation Method Application kit or guidelines Request for Application (RFA) Request for Proposal or Quote Award Instrument Short, may refer to general conditions Describes involvement, party relationships Long, detailed specs, clauses, regulations, and expected results Involvement by Sponsor Generally NoneSubstantial InvolvementMay be extensive Rebudgeting FlexibleUsually flexibleMore restrictive Equipment Title GranteeVaries Peformance Period Specified in GrantSpecified in Coop. Agreement Specified in Contract Patent Rights Generally liberalMay be involvedProvision in contract Publications May ask to be informed Maybe prior review/approval Technical Annual summary reportFrequent reportsDetailed, maybe monthly

14 The Office of Research Services The Office of Research Support Services 13 Revised October 8, 2008 Where to Find Laws & Rules of Grants Administration Read the Notice of Award –Know terms and conditions Awards under the Federal Demonstration Partnership (FDP) Awards under Federal Expanded Authorities but not FDP Non federal awards Federal contracts (Federal Acquisition Regulations)

15 The Office of Research Services The Office of Research Support Services 14 Revised October 8, 2008 General Resources Sponsored Programs Handbook –http://www.upenn.edu/researchservices/Manual.htmlhttp://www.upenn.edu/researchservices/Manual.html Research Services Website –http://www.upenn.edu/researchservices/http://www.upenn.edu/researchservices/ ORSS –School of Medicine –http://www.med.upenn.edu/orss/http://www.med.upenn.edu/orss Financial Policies –http://www.finance.upenn.edu/vpfinance/fpm/http://www.finance.upenn.edu/vpfinance/fpm/ Sponsor’s Websites –http://www.upenn.edu/researchservices/sponsor%20links. htmlhttp://www.upenn.edu/researchservices/sponsor%20links. html

16 The Office of Research Services The Office of Research Support Services 15 Revised October 8, 2008 Office of Management and Budget (OMB) –Works cooperatively with grant making agencies and leads the development of government-wide policy to assure that grants are managed properly and that Federal dollars are spent in accordance with applicable laws and regulations. OMB does not award grants. Federal Awards

17 The Office of Research Services The Office of Research Support Services 16 Revised October 8, 2008 Office Of Management & Budget (OMB) Circulars A-21 Cost Principles for Educational Institutions –Direct costs, F&A, unallowable costs, service centers, etc. A-110 Administrative Requirements for Institutions of Higher Education, Hospitals, and Other Non- Profit Organizations –Reporting and closeout requirements, program income, etc. A-133 Audit Requirements for States, Local Governments and Non-Profit Institutions –Auditee requirements and responsibilities All found at

18 The Office of Research Services The Office of Research Support Services 17 Revised October 8, 2008 OMB Circular A-21 General objectives of A-21 –Government-wide policies on cost reimbursement Standards for cost allowability Standards for cost allocation –Also applies to costs used for cost sharing

19 The Office of Research Services The Office of Research Support Services 18 Revised October 8, 2008 OMB Circular A-21 General Standards for Cost Allowability Costs must be reasonable Costs must be allocable Costs must be treated consistently See SPP #2110 Direct Cost Expenditures

20 The Office of Research Services The Office of Research Support Services 19 Revised October 8, 2008 OMB Circular A-21 Reasonable and Necessary Prudent person rule for reasonableness Is cost necessary for overall operation of the institution or the performance of the sponsored project? Are costs incurred consistent with University policies and procedures?

21 The Office of Research Services The Office of Research Support Services 20 Revised October 8, 2008 OMB Circular A-21 Allocable Cost is incurred for the benefit of only one project or can be readily assigned to multiple projects which directly benefit from the cost –Relative benefits received –Approximated through use of reasonable methods

22 The Office of Research Services The Office of Research Support Services 21 Revised October 8, 2008 OMB Circular A-21 Consistently Treated Requires costs incurred for the same purpose, in like circumstances, to be handled the same way. As Direct or F&A Costs –According to University Policies

23 The Office of Research Services The Office of Research Support Services 22 Revised October 8, 2008 OMB Circular A-21 Direct vs. F&A Costs Direct Costs –Specifically identifiable with a specific sponsored project, an instructional activity or any other institutional activity Facilities and Administrative Costs (formerly referred to as Indirect Costs or Overhead) –Expenses that are incurred for common or joint objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project, an instructional activity, or any other institutional activity

24 The Office of Research Services The Office of Research Support Services 23 Revised October 8, 2008 Direct Costs at Penn Generally should be charged as proposed Department is responsible for maintaining documentation for necessity and appropriateness of direct charges and cost transfers PI is responsible for reviewing and approving all expenditures Authority provided under expanded authorities permits rebudgeting of allowable costs (subject to agency’s terms and conditions)

25 The Office of Research Services The Office of Research Support Services 24 Revised October 8, 2008 F&A Costs The following should generally be treated as F&A costs except for non-federal awards* – –Secretarial and clerical support costs – –Administrative assistants – –Shop personnel – –General supplies and materials Federal exceptions (A-21, Exhibit C) – –Complex programs – –Significant data collection – –Unlike circumstances See SPP #2138 Direct Cost Expenditures for Non-Government OrganizationsSee SPP #2138 Direct Cost Expenditures for Non-Government Organizations

26 The Office of Research Services The Office of Research Support Services 25 Revised October 8, 2008 F&A Rates F&A costs are claimed based on rates Rates are developed by Penn in a periodic F&A Cost Rates Proposal – Currently on three year cycle Proposal is submitted to our cognizant agency, Dept. of Health and Human Services (DHHS), for review, negotiation, and approval

27 The Office of Research Services The Office of Research Support Services 26 Revised October 8, 2008 F&A Rates F&A Rates are applied to the “Base” of the approved award –For federal awards, this base is generally Modified Total Direct Costs (MTDC) MTDC excludes select direct costs such as: –Equipment –Tuition remission –Each subcontract, whose expenses exceed $25,000 On a per subcontract basis

28 The Office of Research Services The Office of Research Support Services 27 Revised October 8, 2008 Determination & Application of F&A Rates Modified Total Direct Cost Base (MTDC) TDC less: Equipment 18XX Tuition ( ) Subcontracts > $25K 5333 Patient Care 5334 Rental Costs 525X

29 The Office of Research Services The Office of Research Support Services 28 Revised October 8, 2008 Salaries of Technical Staff Office Supplies Postage (stamps) Long Distance Charges Entertainment Computer Bad Debts Local Phone Charges Laboratory Supplies Routine Maintenance of Plant/Equipment Federal Express Charges Animal & Care Costs Salaries of Clerical or Administrative Staff* Service/Recharge Centers Library Support Direct or Indirect? End Game

30 The Office of Research Services The Office of Research Support Services 29 Revised October 8, 2008 Direct

31 The Office of Research Services The Office of Research Support Services 30 Revised October 8, 2008 Indirect

32 The Office of Research Services The Office of Research Support Services 31 Revised October 8, 2008 Indirect (with exceptions)

33 The Office of Research Services The Office of Research Support Services 32 Revised October 8, 2008 Neither! These costs unallowable!

34 The Office of Research Services The Office of Research Support Services 33 Revised October 8, 2008 Neither! These costs unallowable!

35 The Office of Research Services The Office of Research Support Services 34 Revised October 8, 2008 Consistent Treatment of Costs Direct CostIndirect (F&A) Cost Salaries of Technical Staff Salaries of Clerical or Administrative Staff Laboratory SuppliesOffice Supplies TravelLocal Phone Chgs EquipmentPostage (stamps) Animal & Care CostsLibrary Support Applicable Employee Benefits Routine Maintenance of Plant/Equipment Service/Recharge CtrsInsurance

36 The Office of Research Services The Office of Research Support Services 35 Revised October 8, 2008 Consistent Treatment of Costs Unallowable Entertainment & Alcoholic Beverages Bad Debts Fines and Penalties Honoraria (lecture fee allowed) Lobbying or Fundraising Costs Contingency Costs

37 The Office of Research Services The Office of Research Support Services 36 Revised October 8, Consistency in estimating, accumulating and reporting costs. 502 Consistency in allocating costs incurred for the same purpose. 505Accounting for unallowable costs. 506Cost accounting period. Cost Accounting Standards for Educational Institutions

38 The Office of Research Services The Office of Research Support Services 37 Revised October 8, 2008 Documenting Allowability of Project Charges Explain necessity of expenditure to successful completion of the project Justifications must address project purposes Justifications must be systematically maintained in file

39 The Office of Research Services The Office of Research Support Services 38 Revised October 8, 2008 OMB Circular A-110 Uniform administrative requirements for grants and other agreements with –Institutions of Higher Education –Hospitals –Other Nonprofit Organizations

40 The Office of Research Services The Office of Research Support Services 39 Revised October 8, 2008 A-110 Provides general guidelines for the administration of grants to federal agencies Agencies have their own implementations of A-110 which communicate their specific requirements –Contained in the Code of Federal Regulations –or on ORS’ home page OMB Circular A-110 (cont.)

41 The Office of Research Services The Office of Research Support Services 40 Revised October 8, 2008 Subpart B: Pre-Award Requirements Most appropriate award instrument? Grant Cooperative Agreement Contract

42 The Office of Research Services The Office of Research Support Services 41 Revised October 8, 2008 Subpart C: Post-Award Requirements Revision of Budget & Program Pre-Award Costs Extensions Carryover Property & Procurement Standards Cost Sharing Program Income Progress Reporting Financial Reporting Record Retention It is within Subpart C that the OMB allows for many of the privileges that are associated with grants under the Federal Demonstration Partnership (FDP).

43 The Office of Research Services The Office of Research Support Services 42 Revised October 8, 2008 Revision of Budget & Program Change in Effort of Key Personnel Key Personnel = Principal Investigator –As well as other individuals responsible for the design, conduct and reporting of project results Absence of PI (for NIH: or key personnel as named in the Notice of Grant Award) for more than 3 months requires sponsor approval Agencies retain approval authority for significant reductions (>25%) in PI effort –(NIH: includes named key personnel)

44 The Office of Research Services The Office of Research Support Services 43 Revised October 8, 2008 Federal Demonstration Partnership Applies to federal grants ONLY Provides more liberal interpretation of OMB Circular A-110 –includes expanded authority to approve certain actions previously reserved to awarding agency Departments must continue to maintain programmatic documentation justifying any changes Specific agency rules vary - review the FDP documentation for details –Available on the FDP internet homepage

45 The Office of Research Services The Office of Research Support Services 44 Revised October 8, 2008 Federal Demonstration Partnership (cont.) Sponsor written approval required prior to significant project changes –For example Changes in scope –Reductions in PI effort (>25%) Programmatic objectives Increase in total costs Transfer of research to another entity unless approved in application Waives many, but not all, required re-budgeting approvals

46 The Office of Research Services The Office of Research Support Services 45 Revised October 8, 2008 With proper justification and documentation, allowable costs for travel, equipment, supplies, consultants, etc., may be reallocated without sponsor permission –Must meet all requirements of OMB Circular A-21 Allows pre-award costs 90 calendar days before the start of the award Federal Demonstration Partnership (cont.)

47 The Office of Research Services The Office of Research Support Services 46 Revised October 8, 2008 Federal Demonstration Partnership (cont.) Unobligated balances –Can be carried over to the next funding period –Can be used to defray costs of any funding period of the project in addition to the current year's funding Allows one no-cost-extension for up to 12 months –ORS must notify sponsor, in writing, prior to end date

48 The Office of Research Services The Office of Research Support Services 47 Revised October 8, 2008 No Cost Extensions For FDP or federal awards under Expanded Authorities (also “Waiver of Authorities”) –University has authority to grant (but must notify agency) –Generally should be requested from ORS at least 30 days prior to the current end date of the award For Non FDP/Expanded Authorities awards, or for non federal awards –A letter to the sponsor requesting extension must include adequate justification –Must be forwarded to ORS to be countersigned prior to forwarding to sponsor Note: Having unspent funds is not adequate justification for an extension

49 The Office of Research Services The Office of Research Support Services 48 Revised October 8, 2008 OMB Circular A-110 Cost Sharing All contributions, including cash & third party in- kind, shall be accepted as part of recipient's cost sharing or matching when such contributions meet all the following criteria –Are verifiable from the recipient's records –Are not included as contributions for any other federally-assisted project or program –Are necessary and reasonable for proper and efficient accomplishment of project or program objectives SPP #2119 Cost Sharing/Matching Requirements SPP #2120 Accounting for Matching Gifts

50 The Office of Research Services The Office of Research Support Services 49 Revised October 8, 2008 OMB Circular A-110 Cost Sharing (cont.) –Are allowable under the applicable cost principles –Are not paid by the Federal Government under another award, except where authorized by Federal statute to be used for cost sharing or matching –Are provided for in the approved budget when required by the Federal awarding agency –Conform to other provisions of Circular A-110, as applicable –Foregone F&A reimbursements are not allowable as cost sharing unless specifically approved by the agency, except for awards under the Federal Demonstration Partnership terms and conditions

51 The Office of Research Services The Office of Research Support Services 50 Revised October 8, 2008 OMB Circular A-110 Program Income Program income earned during the project period –Shall be retained and be used in one or more of the ways listed in the following as defined by the agency (see specific agency’s guidelines) Additive - Added to funds committed to the project by the Federal awarding agency and recipient and used to further eligible project or program objectives (applicable to awards under FDP T&C) Cost Share - Used to finance the non-Federal share of the project or program Deductive - Deducted from the total project or program allowable cost in determining the net allowable costs on which the Federal share of costs is based SPP #2121 Accounting for Program Income

52 The Office of Research Services The Office of Research Support Services 51 Revised October 8, 2008 Subpart D: After-the-Award Requirements Submit Reports Liquidate obligations

53 The Office of Research Services The Office of Research Support Services 52 Revised October 8, 2008 Accounting Procedures of Non- Federal Sponsors Different guidelines for Non-Federal Sponsors alters Penn’s Policies Dependent Care Tuition Object Code 5295: Cost of Space allocated to schools as part of “allocated costs” Object Code 5296: Cost of University Services Object Code 5297: Cost of Space Used by the Project (and not captured as part of 5295) Object Code 5299: School and Departmental Administrative Costs

54 The Office of Research Services The Office of Research Support Services 53 Revised October 8, 2008 Accounting Procedures of Non- Federal Sponsors Not Subject to F&A Object Code 5295: Cost of Space allocated to schools as part of “allocated costs” Object Code 5296: Cost of University Services Object Code 5297: Cost of Space Used by the Project (and not captured as part of 5295) Subject to F&A Dependent Care Tuition Object Code 5299: School and Departmental Administrative Costs

55 The Office of Research Services The Office of Research Support Services 54 Revised October 8, 2008 Questions???


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